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June 19, 2013 12:00 AM

End-to-end testing for MACs prior to ICD-10 conversion just rumor

Joseph Conn
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    Nachimson

    Contrary to its advice for others, the CMS won't require and had never planned to ask its Medicare administrative contractors to test their claims processing systems with outside organizations prior to the scheduled 2014 nationwide conversion to the highly complex ICD-10 revision of diagnostic and procedural codes.

    Rumors have been circulating for several weeks of a decision by the CMS not to do what is also known as “external, end-to-end” testing with outside organizations for ICD-10 claims flows.

    Those rumors were prompted by terse postings on the websites of several of CMS' Medicare contractors, or MACs.

    External trading partners for the CMS and MACs would include claims clearinghouses that work with smaller, less technologically sophisticated providers, as well as those larger and more tech savvy hospitals, medical groups and other providers that directly submit claims to the MACs for reimbursements.

    The CMS is in the process of consolidating15 jurisdictions for its Medicare Part A and Part B contractors down to 10.

    But Cathy Carter, director of the business applications management group in CMS' office of information services, told attendees at a federal hearing Tuesday that “I don't believe there was ever a plan to test with providers all the way through. The announcement everyone is talking about wasn't really an announcement.”

    The MACs were getting questions about testing, and the postings came in response to the questions, Carter said. The federally mandated compliance deadline for ICD-10 conversion is Oct. 1, 2014.

    “We think we have a very rigorous testing process for all of the changes that we make,” Carter said. “We think it's sufficient to make things happen correctly.”

    But, Carter said, “We've heard loud and clear that people are not happy with that. What we have agreed, informally, within the agency, that we would talk about this.”

    Carter's remarks came during the second day of hearings Tuesday by the subcommittee on standards of the National Committee on Vital and Health Statistics, an HHS advisory panel.

    She didn't hold out a lot of hope that things would change even after those internal CMS discussions, however.

    “There is no money or process or time to do this,” Carter said. “All I can say at this point is that we'll go back and have some discussion, and I don't think there is an easy answer for this and I think that whatever we come back with will leave some people unhappy.”

    Several people at the hearing expressed their unhappiness without waiting for CMS officials to confer.

    Holly Louie, a director and chairman of the ICD-10 committee of the Healthcare Billing and Management Association, a trade group for more than 700 professional medical billing companies, said the announcement was “extremely concerning.”

    “There is no software clearinghouse that will solve this,” said Louie, the compliance officer of Practice Management, a Boise, Idaho, billing company. “We really encourage this committee to urge as strongly as possible that Medicare and Medicaid test with their critical trading partners.”

    A survey of more than 1,000 office-based physician practices recently released by the MGMA-ACMPE indicated more than 55% of respondents were “very concerned” about the overall cost of converting to ICD-10 and 70% were very concerned about expected loss of clinician productivity. Testifying Tuesday on behalf of the MGMA was its senior policy adviser, Robert Tennant.

    He, too, didn't like Carter's news.

    “We're spending billions of dollars on meaningful use but nothing on ICD-10 and expecting miracles to happen,” Tennant said.

    Tennant noted that a representative of one of the MAC contractors, National Government Services, presented to the subcommittee Tuesday a series of checklists for various healthcare groups, including health plans, for end-to-end testing of their systems for ICD-10 compliance. NGS prepared the check lists under contract with the CMS and its Web page introducing them says in order for providers, plans and other HIPAA-covered entities to be ICD-10 compliant, they “must perform many steps ... testing their systems with external trading partners to ensure the continuous exchange of administrative information.”

    “The fact that they themselves won't be testing from end to end, I consider to be ironic, and frankly, disappointing,” Tennant said.

    Health IT consultant Stanley Nachimson, chairman of the ICD-10 workgroup at the Workgroup for Electronic Data Interchange, a Reston, Va.-based not-for-profit health information exchange group, said even though the MACs' systems may pass internal tests, absent testing with outsiders, “Medicare will have no idea if the assumptions they made in their system conversions are accurate.”

    And without end-to-end testing with the MACs, he said, “submitters will have no idea if and how their transactions with ICD-10 will be processed.”

    Follow Joseph Conn on Twitter: @MHJConn

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