CMS' reported nixing of end-to-end ICD-10 test irks critics

The CMS has canceled its first scheduled round of end-to-end testing for ICD-10 in the wake of a recent, one-year reset of the compliance deadline to Oct. 1, 2015, according to knowledgeable sources.

But backing off from the schedule is not what several ICD-10 experts and advocates of a trial wanted to hear. They were hoping for a thorough dry run of the healthcare industry's money flow system using the new diagnostic and procedural codes.

“To me, it sends the exact wrong message,” said Stanley Nachimson, a health information technology consultant and ICD-10 expert. That message is: “Let's just wait another five or six months and start up again,” he complained.

In February, after intense lobbying by the American Medical Association, the Medical Group Management Association and others for halting, delaying or otherwise modifying the then-scheduled Oct. 1, 2014 ICD-10 rollout and adding more testing in advance of the implementation date, the CMS relented and agreed to schedule a first round of end-to-end sessions in July.

The physicians' groups kept up the pressure, however, warning that unless the ICD-10 compliance date was altered, the business processes and cash flows of providers could be adversely impacted.

Congress responded in late March, inserting a single sentence in the 123-page, annual Medicare doc fix of the sustainable growth-rate formula, barring HHS from launching ICD-10 before Oct. 1, 2015.

On April 1, President Barack Obama signed the bill into law, making official the delay for at least one year and setting the healthcare industry scrambling to revise what were for many providers, health plans and claims clearinghouses already well-established ICD-10 conversion plans.

Earlier this month, the CMS announced it would issue an interim final rule setting the ICD-10 launch date at Oct. 1, 2015, the earliest date allowed by law. The rule also is expected to require HIPAA providers, payers, clearinghouse and other “covered entities” under the Health Insurance Portability and Accountability Act to continue to use ICD-9-CM through Sept. 30, 2015.

But Nachimson, who confirmed that the CMS had canceled the tests, warned, “Remember the back story on this. They were not going to do testing at all. They had never planned for it and they hadn't budgeted for it, and it was only due to industry pressure that they agreed.”

And, even when the CMS agreed to do end-to-end testing—which means following a claim coded in the new, and far more voluminous and complex, ICD-10 codes from initiation by a provider, to a clearinghouse in some instances, to a payer, through processing, and back to a provider – “they were not going to do extensive end-to-end testing,” Nachimson said. “It was limited. So why not do this limited testing now, learn from it, and then roll it into more extensive work later on?”

The California Medical Association, in an e-mail, also said the CMS had canceled the scheduled tests, adding that “CMS says that additional opportunities for end-to-end testing will be available in 2015.”

The CMS had not confirmed the decision to cancel the testing round by deadline.

Robert Tennant, senior policy adviser to the MGMA, who also confirmed the decision to cancel testing, said it was a mistake that the MGMA will seek to reverse.

“Our perspective is, the only way that ICD-10 can move forward is when all health plans, especially Medicare, are aggressive in performing end-to-end testing,” Tennant said. “Without that, there is potential for disruption in cash flow,” which will in turn affect patient care, he said.

“Even limited testing is extremely helpful for the industry to identify problems and correct those problems,” Tennant said. “We are asking that they go ahead and test with any willing providers. We feel strongly that CMS should take the lead in testing, and the fact that they're delaying testing again is going to raise additional concerns about their readiness.”

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