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GAO Outlook for ICD-10 Raises Questions

 |  By John Commins  
   February 11, 2015

The Government Accountability Office says the Centers for Medicare & Medicaid Services is prepared for the ICD-10 implementation deadline Oct. 1, but an MGMA executive says he does not agree with the GAO audit's findings.

A new federal audit that provides an upbeat assessment of progress towards ICD-10 implementation on Oct. 1 is downplaying some unresolved issues, the Medical Group Management Association says.

In a report requested by the Senate Finance Committee, the Government Accountability Office says the Centers for Medicare & Medicaid Services "has taken multiple steps to help prepare covered entities for the transition, including developing educational materials and conducting outreach, and the majority of the stakeholders we contacted reported that both of those activities have been helpful to preparing covered entities for the ICD-10 transition."

Robert Tennant, director of HIT Policy for MGMA, says he does not agree with the audit's findings.

"They've done a pretty good job explaining the various outreach programs that CMS has instituted to help stakeholders with ICD-10. But I don't quite share the same level of optimism in terms of the readiness," Tennant says. "I don't think they have taken enough steps to make that transition go as smoothly as their proponents think it will."

"For example, only two state Medicaid agencies have completed internal and external testing, as of November, 2014. That's almost two months after the original compliance date. Another 23 states are still updating their policies and systems which needs to occur before test can begin."

"Some people might say 'why worry about Medicaid?' Obviously, [state Medicaid agencies] are not only important, but they are growing in importance in a number of states because of the exchanges and the fact that so many more Americans are now covered under Medicaid because of the expansion. That means more claims. The fact that only two [state Medicaid agencies] have done complete testing is a little bit disconcerting."

Vendors and End-to-End Testing
Tennant says it's also troubling that the federal government does not consider software vendors "covered entities" in the transition to ICD-10. "They are not required by law to upgrade systems, including practice management system software and electronic health record software, but that is absolutely critical if practices are to be successful in their transition," Tennant says.

"We know the problems the industry has faced with software for Meaningful Use Stage 2. Well, it's the same vendors! If they can't achieve success with Stage 2 what does that say about the readiness to move ahead with ICD-10?"

Tennant says questions linger about the scope of the all-important end-to-end testing for ICD-10 readiness in March.

"They are only going to test with 2,550 submitters," he says. "That is not 2,550 physician practices. That is everybody who can submit claims to Medicare; primarily clearing houses, billing services, durable medical equipment suppliers, in-patient care settings, long-term care settings."

"The number of practices and physicians who are going to be able to test with Medicare are just a handful. Will that be sufficient? I highly doubt it."

Another concern is the turn-around time for the testing results.

"Once the testing is completed the information from the testing has to be routed back to the community so they can better understand what the impact of ICD-10 is going to be," Tennant says. "If it takes them two or three months to get the results out, the last round, the most important round, is July. They will not have the results out to the industry until right around the compliance date. That's only a minimal assistance to the industry."

While ICD-10 implementation skeptics were able to delay the deadline for a year, pressure has begun to build from other powerful lobbies in the healthcare sector that want no more delays, including the American Hospital Association.

CMS has estimated that a one-year delay would increase the costs for some providers and payers by as much as $6 billion. Medicare and Medicaid have incurred millions of dollars in costs because of the delay, according to the GAO report.

A 'Significant Percentage… Not Ready to Transition'
Now Congress is taking a closer look at the state of preparedness for the twice-delayed implementation date for ICD-10. Unless Congress takes some as yet unforeseen action, the switch flips on Oct. 1.

Senate Finance Committee Chairman Orrin Hatch (R-UT) and Ranking Member Ron Wyden (D-OR) said in a joint news release that the GAO audit gives them confidence that CMS is preparing adequately.

"As demonstrated by this report, the provider outreach and responsiveness to stakeholder concerns from CMS have kept the agency on track to upgrade to the next level of healthcare coding," Hatch said.

"While additional testing will be needed to ensure its success, the transition to the new system will streamline the management of healthcare records and improve patient care. I will continue to keep a close eye on this issue but see no reason for any delay past the October deadline."

On Wednesday morning, the House Subcommittee on Health is scheduled to examine the status of ICD-10 implementation.

Tennant says MGMA does not anticipate another implementation delay, and is concentrating on making sure the rollout is as smooth as possible.

"We are looking for real leadership on the part of the government to recognize, not at the last minute, not in late September, but [to recognize] a little earlier in the process, after the end-to-end testing is completed, to say there is going to be a significant percentage of the industry who are not ready to transition."

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John Commins is the news editor for HealthLeaders.

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