CMS is moving forward with the switch to ICD-10 whether you’re ready or not, and it won’t test the system before putting your revenue at risk. That decision to go forward without testing how the new process works for physicians is being criticized as hasty and risky.
CMS recently posted a statement on its website saying, “Medicare does not plan to pursue testing of Medicare fee-for-service (FFS) claims directly with providers for ICD-10 at this time. The Centers for Medicare & Medicaid Services (CMS) feels confident that the current level of testing that is done each quarter for any changes to the Medicare claims processing systems is effective to ensure that claims will be processed properly and that ICD-10 diagnosis codes will be accepted and claims will be processed correctly.”
The CMS decision could have disastrous results, says Robert Tennant, MA, senior policy advisor at MGMA.
“The entire industry is going be vectoring toward October 2014 with no guarantee that physician services are going to be paid,” he says. “The potential for catastrophic backlogs of Medicare claims is extremely high.”
Medical Group Management Association President and CEO Susan L. Turney, MD, MS, FACMPE, FACP, wrote recently to HHS Secretary Kathleen Sebelius to protest the decision. The group is “extremely concerned with the Medicare announcement that it will not be conducting ICD-10 end-to-end testing with external trading partners, including physician practices,” she wrote. “We strongly urge that you immediately reverse this policy and expedite Medicare ICD-10 end-to-end testing. This action would decrease the potential of a catastrophic back-log of Medicare claims following the Oct. 1, 2014 compliance date. Failure to do so could result in significant cash flow disruption for physicians and their practices, and serious access to care issues for Medicare patients.”
Turney went on to say, “This deviation from the traditional Medicare testing policy and inconsistent messaging have sharply increased the apprehension that physician practices already feel regarding the implementation of ICD-10.”
CMS officials have expressed surprise that anyone even expected ICD-10 to be tested with physicians before implementation, Tennant says. At the same time, however, CMS is requiring that state Medicaid agencies test the system with providers.
“The reason why this is important is that 5010 was a technical issue. If you had the right format for the claim, chances were you going to get paid,” he explains. “With ICD-10, two types of testing are required. There’s the technical question of whether you are able to insert the ICD-10 code on the claim. But then there’s the question of whether they will pay the claim with that code.”