The first round of the Centers for Medicare & Medicaid Services’ (CMS) end-to-end testing of the ICD-10 code set is complete, with 81 percent of claims accepted. Normal acceptance rates are generally around 97 percent, and physicians are concerned that problems will persist after the Oct. 1 implementation deadline, according a letter from the AMA and 100 other physician organizations to CMS.
The agency conducted the testing, the first of three planned end-to-end testing weeks, to assess readiness prior to the Oct. 1 implementation of the ICD-10 code set. From Jan. 26 to Feb. 3, 661 health care providers, clearinghouses and billing agencies participated with Medicare contractors.
Of the 14,929 test claims received, 81 percent were accepted, according to a CMS press release. Reasons for rejected claims include invalid submission of ICD-9 diagnosis or procedure code (3 percent), invalid submission of ICD-10 diagnosis or procedure code (3 percent) and non-ICD-10-related errors, including issues setting up the test claims (13 percent).
“Testing allows us to identify areas of improvement, and we will work with outside entities and stakeholders to improve those very small deficiencies identified,” CMS Administrator Marilyn Tavenner said in a post on the CMS blog. “And we will continue to do testing, especially in those areas we identify as needing improvement.”
The agency reiterated one point that it said was causing confusion: Physicians must use ICD-9 for services provided before the Oct. 1 deadline and ICD-10 for services provided on or after Oct. 1. That means ICD-10 can only be used for test purposes prior to the deadline, and ICD-9 cannot be used to bill for services provided on or after the deadline. This rule applies no matter when the claim is submitted, so claims submitted after Oct. 1 for services provided before that date must use ICD-9 codes.
Concerns persist among physicians around their ability to ensure claims and payments will be uninterrupted after the compliance deadline. In the letter to CMS, physicians organizations outlined major concerns the agency has yet to address, including:
- The lack of detailed data about the end-to-end testing results. So far, CMS has released only general data—not broken out by type and size of providers and specific details about problems encountered.
- Questions surrounding Medicare’s ability to correctly collect and calculate quality data during and after the transition to ICD-10 under the meaningful use program and the Physician Quality Reporting System. These programs’ reporting periods straddle the ICD-10 implementation date, potentially causing confusion. CMS has not discussed how it plans to address and correctly tabulate quality performance reporting metrics.
- The need for risk mitigation. One of the most significant risks of moving to ICD-10 is the likelihood for claims processing and cash flow interruptions, making it vitally important that CMS be prepared with extensive contingency plans. For example, CMS could grant advance payments to physicians experiencing a dire financial hardship as a result of the change to the new code set.
- Ensuring software vendor readiness. Many electronic health record (EHR) vendors were behind in delivering upgrades to certified EHR software for the meaningful use program, indicating that vendors may not be ready to deliver needed ICD-10 upgrades.
“Physicians are being asked to assume this significant change at the same time they are being required to adopt new technology, re-engineer workflow and reform the way they deliver care—all of which are challenging their ability to care for patients and make investments to improve quality,” the letter said.
CMS will host two more end-to-end testing weeks before the implementation deadline:
- April 27 through May 1, for which volunteers have already been selected
- July 20 through July 24, for which volunteers may apply beginning March 13
The agency is hosting acknowledgment testing this week, and will host another period June 1-5. During acknowledgement testing, physicians can test if their claims are received by CMS. No registration is required to participate.
The agency said it would conduct tester education prior to the remaining testing weeks to avoid non-ICD-10-related errors.
Physicians should also note that CMS is updating its coverage decisions to reflect the new code set—review the updated coverage policies.
ICD-10 implementation
The AMA will continue to urge regulators to ease the burden of ICD-10 implementation on physicians. In the meantime, practice management experts advise physicians to now begin preparing their practices for the transition to ICD-10.
To help with the testing process, the AMA has developed an ICD-10 data file available on CD-ROM or via immediate download. Additional information and resources to help physicians get ready for ICD-10 are available on the AMA ICD-10 Web page.
