The Medial Group Management Association (MGMA) is continuing to urge CMS to conduct more complete ICD-10 end-to-end testing than currently planned. While CMS has taken a step back from its previous stance that it felt sufficiently prepared to handle the transition with no further testing, MGMA believes that HHS isn’t going far enough to ensure a successful implementation for providers.
ICD-10 testing has long been a worry for MGMA, which has continually petitioned CMS to help formulate a more cohesive and robust plan to lead the industry forward as it lurches haphazardly towards the October 1, 2014 implementation date. “This inconsistent messaging has sharply increased the apprehension that physician practices already feel regarding the implementation of ICD-10,” Susan L. Turney, MD, MS, FACMPE, FACP, President and CEO of MGMA wrote in July. Medicare is currently planning a front-end “testing week” in March of 2014, but that will not be enough to guarantee compliance, Turney adds.
“End-to-end testing between trading partners is absolutely critical to measure operational predictability and readiness,” December’s letter states. “In addition, commercial health plans traditionally take their direction on these types of operational issues directly from Medicare. With Medicare refusing to engage in end-to-end testing with their physician practice partners it is likely that many of these commercial plans will also not test.”
Instead of a week of testing, MGMA suggests that providers be allowed to conduct full end-to-end testing with Medicare throughout a whole quarter of 2014 in order to provide ample time to identify potentially critical issues. Providers should receive feedback from CMS in order to determine how ICD-10 will impact payment rates, and CMS should release a report on industry readiness to help providers gauge their efforts. Other recommendations include greater cooperation with stakeholders such as commercial health plans and the public release of readiness levels for all Medicare Administrative Contractors and state Medicaid agencies on a monthly basis.
“If the transition to ICD-10 results in wide-scale interruption to the nation’s claims processing system, the ability of healthcare providers to continue operations could be significantly impacted,” Turney warns. “While end-to-end testing will not ensure that this disruption will not take place, it will provide increased assurance to physician practices and other industry stakeholders that claims will be processed and highlight well before the compliance date any additional steps necessary for implementation.”