The American Hospital Association (AHA) is putting pressure on CMS with a new open letter stating the importance of thorough and timely ICD-10 testing. Addressed to Deputy Administrator and Director for the Center for Medicare Jonathan Blum, the letter stresses that ICD-10 testing should begin no later than January 2014 and include all hospitals, not just the largest facilities with the most claims.
“Hospitals across the country have invested significant financial and human resources in preparing for the transition to ICD-10 that will occur on Oct. 1, 2014,” writes Linda E. Fishman, Senior VP of Public Policy Analysis and Development at the AHA. “Our members have told us that they are ready, or nearly ready, to start external testing with CMS and others. Therefore, we were concerned to read recent news articles stating that the agency would not undertake external testing of ICD-10 due to a lack of funding within the agency, according to a CMS official.”
The AHA has been optimistic about its members’ readiness since the summer, when 90% of facilities reported their high confidence about their ability to reach the October 1, 2014 deadline in good form. However, end-to-end testing with all health plans, including Medicare and Medicaid, is a crucial piece of the puzzle, not only necessary to ensure smooth transactions, but a requirement of the Affordable Care Act, Fishman reminds CMS. And due to the complexity and scale of the project, it is important to insure adequate time and to include small hospitals, which suffered during the 5010 transition due to poor planning on their behalf.
“To provide sufficient time for testing by all providers by the end of June, it is important that the external testing begin no later than January 2014,” the letter recommends. “Indeed, a survey we conducted earlier this year indicated that most hospitals are targeting January 2014 through June 2014 for external testing with their partners. Some have already begun testing with private-sector payers.” Fishman says that there are two requirements for successful testing: ensuring proper connectivity and transaction exchange for ICD-10 claims and testing the provider’s and payer’s ability to correctly handle ICD-10 content inherent in the new standards.
“The AHA stands ready to assist CMS in defining the specifics of the testing process and disseminating information about it,” the letter concludes. “The transition to ICD-10 is important to our understanding of health care delivery and requires cooperation from all parties – health care providers, public and private payers and clearinghouses. As the clock runs out on preparation time, all parties must re-double their efforts to ensure a smooth and timely roll-out of the project. We urge CMS to take the necessary steps to conduct all necessary testing for ICD-10 and stand ready to help in the process.”