“Do as I say, not as I do” is the motto for CMS when it comes to conducting thorough external testing with ICD-10 business partners. Despite its insistence that providers, clearinghouses, and payers lavish attention on their technical capabilities ahead of ICD-10, Medicare administrative contractors (MACs) are not required to conduct testing with any of their partner organizations, and have no plans to do so. Medicare officials feel that their regular quarterly testing procedures are more than sufficient to handle incoming ICD-10 claims, regardless of the fact that the rest of the industry has absolutely no idea if they will have the capabilities to successfully submit their claims.
Medicare contractors work with the same organizations as most providers: clearinghouses, hospitals, and medical groups that submit claims to the MACs for fee-for-service reimbursement. Yet the MACs won’t be testing their connections with those partners, and providers will be unable to conduct sample transactions before October 1, 2014 to see if their own infrastructure is up to scratch. In a short announcement that has been stirring up questions for the past few weeks, CMS states that they will be doing some internal testing of their systems, since they plan to be ready for ICD-10 a full year ahead of schedule, but that’s about it.
“I don’t believe there was ever a plan to test with providers all the way through,” said Cathy Carter, Director of the Business Applications Management Group in the CMS Office of Information Services during a hearing this week. “The announcement everyone is talking about wasn’t really an announcement. We think we have a very rigorous testing process for all of the changes that we make. We think it’s sufficient to make things happen correctly.”
But providers who are pouring time, money, and staff hours into preparing for this federally-mandated transition are none too pleased that CMS is dictating the rules without shouldering the same burden. “The fact that they themselves won’t be testing from end to end, I consider to be ironic, and frankly, disappointing,” said Robert Tennant, Senior Policy Advisor for MGMA, which recently released a survey with some alarming statistics about the state of the industry’s preparations. “We’re spending billions of dollars on meaningful use but nothing on ICD-10 and expecting miracles to happen.”
The fact that CMS contractors won’t be conducting extensive testing is even more incentive for providers to ensure that all of their own systems are working before the compliance date. After all, it’s really all they can do if they’re not going to get a helping hand from the other end.
While Carter said that the outcry has prompted some internal discussion about instituting eternal testing procedures to appease worried providers, she doesn’t believe much will come of it. “There is no money or process or time to do this,” she 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.”