Testing, lack of contingency planning among docs' biggest ICD-10 concerns

Providers continue to be at odds when it comes to the forthcoming implementation of ICD-10.

On March 3, 22 health systems and representative organizations urged several members of Congress--including Rep. Fred Upton (R-Mich.) and Sen. Orrin Hatch (R-Utah)--to move forward with ICD-10 without delay. In their letter, the authors reiterated that the "outdated" ICD-9 system is more than 30 years old and uses "obsolete" terminology and codes.

"The ICD-10 code set strengthens the types of data recorded, the specificity and exactness in describing a patient's diagnosis, and in classifying inpatient procedures," the letter said. "ICD-10 is therefore a critical tool in aiding quality improvement and patient safety efforts in our systems."

However, one day later, 100 physician groups--led by the American Medical Association--sent a letter to Acting Centers for Medicare & Medicaid Services Administrator Andrew Slavitt expressing several issues with the transition. Among their concerns:

Testing: The physician groups took issue with both CMS' prior acknowledgement testing and its current end-to-end testing efforts. The former, they said, is limited in that it only tested that a claim would be initially accepted through the claims processing system. "It provides no information about if and how the claim will process completely, ensuring payment to physicians," the letter said.

Meanwhile, end-to-end testing, the groups argued, will only be conducted with "a small fraction of all Medicare providers and an even smaller universe of claims submitted each year." They also called the acceptance rates touted by CMS after the first week of testing "well below average."

Quality measurement: "We foresee unintended consequences for measure denominators and measure rates due to potentially conflicting timelines," the groups said, pointing out that while ICD-10 is scheduled to begin on Oct. 1, the Physician Quality Reporting System and Meaningful Use quality reporting periods are based on the calendar year. The groups argued that many Meaningful Use and PQRS measures will need to be reported in ICD-9 initially, and then in ICD-10 for the last few months of 2015.

"CMS has not discussed how it plans to address and correctly tabulate quality performance reporting metrics after the transition to ICD-10," they said.

Risk mitigation: Because moving to ICD-10 could cause claims processing and cash flow interruptions, the groups said, CMS should mitigate such risks by granting advanced payments--"reimbursements outside the normal claims processing system for services already rendered, such as paper checks," for doctors who experience "dire financial hardship."

Prior HIPAA mandates, including the National Provider Identifier and the upgrade to Version 5010 transactions--the groups argued--all wound up causing "significant disruptions," despite being less complex than ICD-10.

"The likelihood that Medicare will reject nearly one in five of the millions of claims that go through our complex healthcare system each day represents an intolerable and unnecessary disruption to physician practices," AMA President Robert Wah said in a statement. "Robust contingency plans must be ready on day one of the ICD-10 switchover to save precious healthcare dollars and reduce unnecessary administrative tasks that take valuable time and resources away from patient care."

To learn more:
- here's the letter opposing delay (.pdf)
- check out the letter outlining concerns (.pdf)
- here's the AMA announcement

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