CMS declares it's ready for ICD-10 implementation

Carl Natale
by Carl Natale

It's worth remembering that late in 2013, the Centers for Medicare and Medicaid Services (CMS) said it didn't need ICD-10 end-to-end testing

Then imploded, and CMS officials tried to explain why they didn't conduct extensive testing on the website.

The reason was that they already tested their systems and knew that they were able to accept ICD-10 codes without a problem.

But they changed their minds and scheduled end-to-end testing.

The latest round was conducted in January, and CMS Administrator Marilyn Tavenner declared testing was successful. By successful, she meant about 3 percent of test claims were rejected because of "Invalid submission of ICD-10 diagnosis or procedure code." I wonder how many were intentional errors for the sake of negative testing.

It would be interesting to see what kind of ICD-10 codes were commonly misused.

Overall, only 19 percent of test claims were rejected. Here's the CMS breakdown:

  • 3 percent: Invalid submission of ICD-9 code
  • 3 percent: Invalid submission of ICD-10 code
  • 13 percent: Non-ICD-10 errors — for example:
    • Incorrect NPI
    • Health Insurance Claim Number
    • Submitter ID
    • Dates of service outside the range valid for testing
    • Invalid HCPCS codes
    • Invalid place of service

Which leads Tavenner to declare that the industry is ready to modernize healthcare.

Not so fast

CMS used Thursday's National Provider Call to evangelize the benefits of ICD-10 coding and explain testing programs.  But many providers expressed concerns that they would not get the chance to participate in the testing.

There was no information on whether those concerned providers were able to test with their commercial healthcare payers or clearinghouses.

While I understand CMS is trying to project optimism, I'm not sure if they should. Navicure released survey results on the state of ICD-10 preparation. According to Navicure:

  • Physician practices have a lot of work to do (so they're not trying to get in on Medicare end-to-end testing.)
  • Lack of system updates from healthcare vendors is holding them back
  • But they're confident they can get it done by Oct. 1
  • Which they believe will really be the final ICD-10 deadlline

Despite that optimism, they're worried about healthcare payers not being ready.

So despite CMS confidence in taking the next step to modernize healthcare, there are a few more issues out there.

ICD-10: “What to leave in, what to leave out”

  • While physicians complain of the number of ICD-10-CM codes, the American Urological Association wants to add 199 diagnosis codes.
  • Much demand is driven by new quality-based revenue models mandated by Congress. (Not sure that's the proper cause and effect sequence.)
  • "We may all long for simpler times, but with the advances in medicine and the policy mandates of Congress, simpler times are a thing of the past."
  • Much of the increase is specificity is due to organization — such as laterality or trimester designations in obstetrics.

(Coalition for ICD-10)

The GEMs are ICD-10 Training Wheels

  • Rhonda Butler writes that the General Equivalency Mappings (GEMs) were meant to help healthcare organizations get used to ICD-10 coding.
  • Organizations need to quickly move into deeper analysis.

(3M HIS Blog)

HIMagine That! Don’t Just Hope…Take Action!

Sue Belley, RHIA, and Donna Smith talk about the U.S. House Energy & Commerce Subcommittee hearing on ICD-10 implementation (3M HIS Blog)

RelayHealth ICD-10 Testing Yields Industry-Leading Acceptance Rates, Claims and Remittance Volumes

  • RelayHealth announced it has been kicking butt when it comes to ICD-10 testing.
  • They claim a record number of healthcare provider test claims and payer remittances.