Health Information Management

CMS to offer ICD-10 end-to-end testing, but will it matter?

APCs Insider, February 21, 2014

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CMS announced this week that it will conduct end-to-end testing for ICD-10 in summer 2014 after facing continued scrutiny from providers and Congress about the planned October 1 implementation of the new coding system.
It may just be a coincidence that CMS made this about face the same week the AMA released yet another call for delayed implementation in a letter to Secretary of Health and Human Services Kathleen Sebelius. But it was also called out by four Senators, all physicians, for the worrisome "brevity and limited scope" of the only other previously planned testing of front-end systems in March.
That testing, planned for March 3-7, will allow providers, billing companies, and clearinghouses to determine whether CMS will be able to accept their claims with ICD-10 codes. Claims will not be adjudicated, but MACs will return an acknowledgement to the submitter to confirm if the claims would be accepted or rejected.
After the disastrous rollout of amidst a variety of technical glitches, however, it's easy to agree that such a limited test could not truly show whether providers, insurance companies, and other parties would be ready for ICD-10. In addition to announcing end-to-end testing, CMS also said it will explore additional weeks of acknowledgement testing after analyzing results of the March test.
CMS released very few details about the end-to-end testing, only saying it will occur in summer 2014 for "a small sample group of providers," with more details to be released at a later date. These types of details are critical for providers to truly understand if they will be ready to flip the switch on October 1 when their reimbursement will count on a seamless technical transition.
In fact, the decision to perform end-to-end testing raises more questions than it answers. If there are complications during the end-to-end testing, will CMS even be able to disseminate the results and inform providers how to avoid them before implementation? Will it be able to gather a representative cross-sample of providers to test?
CMS offering end-to-end testing is a step in the right direction, but if it doesn't give all providers a chance to assuage their ICD-10 implementation concerns by allowing enough time and information to correct them, the call for more delays will only continue as we get closer to October 1.

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