Although the CMS now intends to require its Medicare contractors to test their ICD-10 performance, the Medical Group Management Association is calling the plans “simply insufficient.”
The agency previously did not intend to require ICD-10 testing for Medicare contractors before the massive transition to the revised set of diagnostic and procedure codes set for Oct. 1, 2014.
The CMS, which is holding fast to the implementation date, recently announced (PDF) that a “testing week” will be held March 3 through March 7, 2014, for MACs and their trading partners “to generate awareness and interest and to instill confidence in the provider community that CMS and the MACs are ready and prepared for the ICD-10 implementation.”
The MGMA, which represents 33,000 medical practice administrators and executives, welcomed the agency's reversal but said the limited testing the CMS envisions will do little to calm the nerves of physician practices as the transition draws near.
Robert Tennant, the association's senior policy adviser on federal legislative and regulatory health information technology issues, said that it appeared the CMS might be “spooked” by the problems experienced during the HealthCare.gov roll out and may be more open to testing.
“We'll keep harassing them until they do what the industry needs,” Tennant said, adding that he's “cautiously optimistic” that the CMS will conduct the level of comprehensive ICD-10 testing that's required.
In a letter (PDF) to HHS Secretary Kathleen Sebelius, the MGMA noted that the “front end” testing the CMS has planned falls short of the rigorous end-to-end external checks involving all participants in the healthcare claim stream—such as providers, claims clearinghouses and payers—that is required to ensure the system will function properly.
“First, (end-to-end) testing permits software developers, such as those in the practice management system and electronic health record field, to ensure that software can be appropriately configured for physician practices,” Dr. Susan Turney, MGMA president and CEO, said in the letter to Sebelius. “Second, end-to-end testing can identify critical problems well prior to the Oct.1, 2014 compliance date and permit trading partners to institute the appropriate modifications to systems and/or workflow. Finally, end-to-end testing is the only practical method practices will have to accurately predict and respond to Medicare coding edits and fully understand the impact that ICD-10 will have on reimbursement.”
Turney said CMS contractors should conduct end-to-end testing with a sufficient and diversified set of providers so that the most common claim-adjudication issues can be identified and should do so on a quarterly basis. She also recommended the CMS publicly report the ICD-10 readiness of MACs and state Medicaid agencies on a monthly basis, and work to determine the readiness of commercial health plans and electronic health record vendors.
While not responding to the MGMA's specific suggestions or concerns, the CMS did reply with a general statement on ICD-10 implementation.
“CMS is committed to implementing ICD-10 on Oct. 1, 2014, and that will not change,” according to the statement from CMS spokeswoman Rachel Maisler. “We are also committed to continuing to process provider claims in a timely and effective manner once the ICD-10 code sets go into effect. We are working very closely with all industry stakeholders to provide industry support in transitioning to ICD-10.”
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