MGMA Urges 'End-to-End' ICD-10 Testing

Failure to comprehensively test the ICD-10 diagnostic coding system will dramatically increase the potential of catastrophic cash flow disruption for physicians practices, says the Medical Group Management Association.

The October 2014 roll out of ICD-10 could become a fiasco of epic proportions unless the federal government mandates more rigorous "end-to-end" testing of the complex diagnostic coding system to ensure that it actually works, the Medical Group Management Association told the federal government this week.

In a letter Monday to Health and Human Services Secretary Kathleen Sebelius, MGMA President Susan L. Turney, MD, commended the government's decision to initiate testing of ICD-10. However, Turney called the planned "front-end" testing that determines if providers can file claims correctly "simply insufficient. We strongly urge that the agency undertake full end-to-end testing with physician practices as soon as possible."

"Failure to appropriately test ICD-10 could result in operational problems similar to what the department experienced with the rollout of healthcare.gov and will dramatically increase the potential of catastrophic cash flow disruption for practices following the Oct. 1, 2014 transition date," Turney said in the letter.

"Complete end-to-end testing is critical for a number of reasons. First, this type of comprehensive testing permits software developers, such as those in the practice management system and electronic health record field, to ensure that software can be appropriately configured for physician practices."

"Second, end-to-end testing can identify critical problems well prior to the Oct. 1, 2014 compliance date and permit trading partners to institute the appropriate modifications to systems and/or workflow. Finally, end-to-end testing is the only practical method practices will have to accurately predict and respond to Medicare coding edits and fully understand the impact that ICD-10 will have on reimbursements."

Turney said that "end-to-end testing between trading partners is absolutely critical to measure operational predictability and readiness."

"In addition, commercial health plans traditionally take their direction on these types of operational issues directly from Medicare. With Medicare refusing to engage in end-to-end testing with their physician practice partners it is likely that many of these commercial plans will also not test," she said.

'A Little Hyperbole'
Turney noted that the healthcare industry was wracked by confusion with the transfer in January, 2012 to HIPAA Version 5010. She said that a failure to identify issues with ICD-10 "well before the compliance date will lead directly to a protracted industry implementation and significant disruption of cash flow for a large number of physician practices. With HIPAA Version 5010, more testing and better dissemination of the testing results could have averted many of the problems that practices, clearinghouses, health plans, and software vendors experienced prior to and immediately after their 'go live' dates."

Steve Sisko, an Arizona-based healthcare industry consultant, says that MGMA is exaggerating the effect of potential snafus in the ICD-10 rollout.

"I do believe the MGMA is trying a little hyperbole to leverage the current 'government can't get it right' fervor for their anti-ICD-10 agenda," Sisko said in an email exchange with HealthLeaders Media. "I think that providers have to be careful with making a big deal out of ICD-10 and playing it as something the payers will drop the ball on. My sense is that it's the providers who are lagging with their ICD-10 migration and conversion efforts. The providers tried this same approach when 5010 was hiccupping last year and was granted an enforcement delay."

"Personally I don't think the two efforts are comparable and while I suppose anything is possible, I don't think any issues associated with the ICD-10 rollout will be major or as concentrated in certain functional areas like the HIX rollouts. I do suspect there will be some problems – relatively minor – that will be blown out of proportion."

'Nobody Seems to Be Ready'
But Robert Tennant, a senior policy advisor at MGMA, says the comparison is apt. "What the exchanges showed us was that if you don't test and you just go live with something, you run the risk of problems. And ICD-10 is a massive list for the industry and for Medicare," Tennant says.

"There are a lot of moving parts here that have to flow together in order for this change to happen. Part of it is the practice management and electronic health records software vendors have to upgrade their products' clearinghouses. The vast majority of claims are submitted through clearinghouses and they are telling us they have not received the claim edits from the health plans, including Medicare, including the policies and procedures that wrap around these codes. We are all vectoring towards this October date and nobody seems to be ready, and that includes the government."

"ICD-10 is a better code set. We'd be the first to agree with that. But we have to ensure that the implementation process is done in a way that is not dramatically negative for physician practices. We are very concerned about the potential of productivity decreases from both clinicians and coders and also concerns about the cash flow disruption following the October date.

Tennant says he hopes the HIX rollout fiasco and the potential political fallout have made HHS more sensitive to concerns raised by healthcare providers.

"They are acutely aware that though the ICD-10 mandate was under President Bush's watch, this is going to be seen as an extension, rightly or wrongly, of President Obama's policies," he says. "It is incumbent upon CMS to take every step possible to ensure that the transition, if it goes forward, is a successful one. Right now the first thing they can do is begin to test."

Topping a list of recommendations, MGMA called on CMS to expand the existing Medicare front-end testing week in March 2014 to permit complete end-to-end testing with any willing physician practice.

"This testing should include return of the remittance advice to allow practices to clearly determine how ICD-10 will impact their reimbursement rates," Turney said. "If you are unable to provide testing services for all willing providers, we urge you to conduct end-to-end testing with a sufficient number and breadth of specialties to facilitate the identification of the most common claim adjudication issues."