CMS agrees on end-to-end testing for ICD-10

It was not an easy fight for vocal opponents of the Centers for Medicare and Medicaid Services' testing program for ICD-10, but after several highly publicized letters and charged criticism, the CMS has given way and agreed to exhaustive end-to-end testing of their and providers' systems for the new medical billing processes. While physicians' struggles with electronic health records have left some organizations feeling unsatisfied with the compromise, others have praised it as a significant improvement for practices that may be currently overwhelmed as they prepare to mitigate disruptions caused by EHR implementation as well as the Oct. 1 transition.

CMS compromises on testing
In a memo released late Feb. 19, the CMS announced that, contrary to prior statements, it would invite a small group of providers to participate in an end-to-end test of the ICD-10 system in the summer. These tests would demonstrate that "providers or submitters are able to successfully submit claims containing ICD-10 codes to the Medicare claims systems," and that comprehensive and accurate reports of the submissions are provided to the claimants.

Before the news, the CMS had only agreed to acknowledgement testing, a system where providers would be notified if their simulated claim had been accepted or rejected. The CMS would provide no further information to providers, leading many critics to wonder if the agency's own internal systems would be prepared to deliver payments and confirmations in a timely manner come Oct. 1.

While acknowledgement testing remains open to any providers who apply, the new end-to-end program will operate on an invite-only basis. Only a few providers will be asked to participate, but the CMS plans to invite a representative sample of providers so that the results of the test will prove beneficial for those organizations who do not test with it directly.

Health care groups win a hard fought battle
The change in policy from the CMS comes after repeated open letters and vocal criticism of the limited testing program by several physician-advocate groups. The American Medical Association, American Medical Association and Medical Group Management Association all expressed gratitude that the CMS responded to their concerns with concrete action.

"The AHA is pleased that CMS will be moving forward with end-to-end testing that will include claim adjudication," the group told Health Data Management. "Extensive, end-to-end testing is crucial to ensure a smooth transition from ICD-9 to ICD-10."

While the MGMA expressed similar sentiments, the AMA was not impressed. By far the most vocal of the three groups as it relates to opposition to the ICD-10 transition, the AMA was not satisfied with the limited sample size of the end-to-end testing and called for a more concerted effort by the CMS to enumerate the true impact of changeover on practices that it claims are still in danger of serious revenue losses.

"While the AMA is pleased by the federal government's decision today to conduct end-to-end ICD-10 testing, the AMA continues to urge CMS to reconsider the ICD-10 mandate during a time when physicians are struggling to keep up with many other costly, federal mandates," the group told Health Data Management. Among the AMA's specific concerns that it feel the CMS has not adequately address are the heavy cost that EHR implementation is predicted to have on small practices and evolving meaningful use requirements. In addition to ICD-10 preparation, the AMA claimed that physicians are not being given a fair chance to train their staffs and learn new software practices. The group once again called for a postponement or outright repeal of ICD-10.