ICD-10: CMS Agrees to Limited End-to-End Testing

Following concerns from physicians and some US senators, CMS says it will do end-to-end ICD-10 testing with a small sample group of providers selected to represent "a broad cross-section of provider types, claims types, and submitter types."

In an apparent nod to concerns raised by physicians, payers, hospitals and Congress, the federal government said Wednesday that it would conduct limited "end-to-end testing" of the new ICD-10 diagnostic coding set this summer with "a small sample group of providers."

"End-to-end testing includes the submission of test claims to [the Centers for Medicare & Medicaid Services] with ICD-10 codes and the provider's receipt of a Remittance Advice (RA) that explains the adjudication of the claims. The small sample group of providers who participate in end-to-end testing will be selected to represent a broad cross-section of provider types, claims types, and submitter types," CMS said in a memo to providers.

The goal of the end-to-end testing is to demonstrate that:

• Providers can successfully submit claims containing ICD-10 codes to the Medicare FFS claims systems.
• CMS software changes made to support ICD-10 result in appropriately adjudicated claims based on the pricing data used for testing purposes.
• Accurate Remittance Advices are produced.

Details about the end-to-end testing process will be disseminated "at a later date," CMS said.

ICD-10 is scheduled to go live on Oct. 1, despite the complaints from many in the provider community that they aren't ready. The American Hospital Association and the American Medical Association have called for delays in ICD-10 implementation or at least more comprehensive end-to-end testing to allow providers, payers and software vendors to more thoroughly test their systems.

The AMA last week released a study it sponsored showing that projected physicians' implementation costs for the federally mandated ICD-10 medical coding set will be as much as three times higher than initial estimates. Along with the study, AMA President Ardis Dee Hoven, MD, released a copy of the letter she sent to Health and Human Services Secretary Kathleen Sebelius asking her to "strongly" reconsider the ICD-10 mandate.

On Wednesday, Hoven offered guarded praise of CMS's decision to conducted limited end-to-end testing.

"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," Hoven said in prepared remarks.

"The AMA urges CMS to conduct the testing as soon as possible and to ensure that there is an adequate sample which includes a variety of different sized medical practices and specialties."

The AMA continues to work toward the implementation deadline even though its House of Delegates has called for the repeal of ICD-10. "Adopting ICD-10, while it may provide benefits to others in the healthcare system, is unlikely to improve the care physicians provide their patients and takes valuable resources away from implementing delivery reforms and health information technology," Hoven said Wednesday.

CMS was also feeling pressure from Congress to address the concerns raised by providers. This week, four Republican U.S. Senators—all of them physicians—sent a letter to CMS Administrator Marilyn Tavenner questioning the plan to conduct limited "front-end" testing for ICD-10.

"Given the size and scope of the potential transition to ICD-10, the brevity and limited scope of this test is worrisome, said the letter, signed by Sens. Tom Coburn, MD (R-OK), John Barrasso, MD (R-WY), John Boozman, OD (R-AR), and Rand Paul, MD (R-KY).

"This change will impact millions of physicians and patients, and hundreds of billions of dollars in payments that flow through Medicare and Medicaid. Other major federal IT projects—such as the implementation of Healthcare.gov—have demonstrated the importance of thorough pre-testing every aspect of new systems, both the front-end and back-end components. System-wide errors and delay could adversely impact both patients' own pocketbooks and provider cash flows."