The CMS would seem to be adequately preparing to implement ICD-10 by its Oct. 1 deadline, said Sens. Orrin Hatch (R-Utah) and Ron Wyden (D-Ore.) Friday in a joint statement. They based that outlook on commentary in a new Government Accountability Office report delivered to Congress.
Hatch and Wyden, the chairman and ranking member of the Senate Finance Committee, said the report “gives them confidence” the CMS is doing what's necessary for the switch.
The 41-page report, while drawing no conclusions about preparedness, offered a list of achievements and raised some red flags on the CMS' readiness for the switch to the ICD-10 diagnostic and procedural codes.
GAO investigators heard the concerns of 28 healthcare industry groups, including representatives from the American Health Information Management Association, Medical Group Management Association, Workgroup for Electronic Data Interchange, Healthcare Billing and Management Association, American Medical Association and several medical specialty societies, and looked at how the CMS addressed their issues.
Documentation from the CMS “states that the agency completed all ICD-10-related changes to its Medicare fee-for-service claims-processing systems” based on internal testing, the GAO said.
GAO was not able to include results of last week's external, end-to-end testing of Medicare claims-processing systems with more than 800 organizations in the Medicare claims-processing cycle. The external testing rounds were requested by providers—and somewhat reluctantly granted by the CMS.
Not having those test results raises a red flag about the report for some. The aim of end-to-end testing is to identify problems with the new codes anywhere they might surface in the claims-processing cycle. Not knowing how the test turned out means critical information about preparedness is missing from the report.
Another, more significant warning sign went up in the report about the ICD-10 readiness of state Medicaid agencies.
While the CMS “provided technical assistance” to various state Medicaid agencies as of November 2014, not all agencies had started internal testing on their systems' abilities to accept and adjudicate claims in ICD-10, the report noted.
All Medicaid agencies reported, however, that they would be able to perform “all of the activities that CMS has identified as critical” by the Oct. 1 deadline, the GAO said.
That wording prompted a skeptical reaction from Stanley Nachimson, a health IT consultant and ICD-10 specialist.
The CMS has “provided technical assistance and they're sending people out all the time, but they have not communicated the current status of all Medicaid state agencies,” Nachimson said.
“I continue to be a little concerned that the industry relies too much on CMS to get all this educational activity out there,” he said. “The entities themselves need to engage in that. There needs to be a much more coordinated effort. You can't just say CMS needs to do the education. I'd like to see the health plans and provider organizations do a little bit more to provide service to their members.”
He's not heard anything yet on how last week's end-to-end testing went, either from private sector or Medicare participants. One issue is that each test participant was limited to submitting just 50 claims.
“That's not really a wide variety,” he said. “It certainly will benefit Medicare to see how their systems are operating. But the entities on the other side don't have the same chance to really shake out their partners.”
Still, he's optimistic that this time, after multiple delays, the ICD-10 deadline will hold. But that's not to say the transition will go smoothly for everyone.
“The vast majority of health plans will be ready in some way, shape or form,” Nachimson said. But, depending on size and provider type, he estimates anywhere from 15% to 25% of providers not being ready.
“You've got people who are still just not interested in doing it,” he said.
Follow Joseph Conn on Twitter: @MHJConn