The American Medical Association in a March 4 letter to the Centers for Medicare and Medicaid Services, along with 99 state and specialty societies, has urged CMS to come up with contingency plans to address their concerns about the potential negative impact of the ICD-10 transition.

The 100 physician groups, including AMA, expressed their concerns to CMS Acting Administrator Andrew Slavitt that there are not sufficient contingency plans in place to avoid serious disruptions that could occur on or after October 1—the ICD-10 implementation deadline. Without these contingency plans, the groups argue the code switchover could result in a “catastrophic” backlog of millions of dollars in unpaid Medicare claims.

“By CMS’ own analysis, one of the most significant risks to moving to ICD-10 is the likelihood for claims processing and cash flow interruptions,” the letter states. “It is therefore vitally important that CMS is prepared with extensive contingency plans in the event that these feared disruptions occur.”

The physician groups argue that previous HIPAA mandates, such as the National Provider Identifier (NPI) and the upgrade to Version 5010 transactions—resulted in “significant claims processing disruptions that caused physicians to go unpaid for weeks and sometimes months.” However, they make the point that “these implementations were less complex than ICD-10 and still resulted in significant disruptions.”

The letter references recently released results from ICD-10 end-to-end testing that revealed an 81 percent claims acceptance rate. The coalition of physician groups called the acceptance rate “well below average” and stated that they “continue to be concerned about the limited scale of testing being performed.”

The testing, conducted January 26 to February 3, included 661 providers as well as all Medicare Administrative Contractors, with billing companies submitting nearly 15,000 test claims. Yet, due to the fact that the testing only represents less than one percent of all Medicare claims and likely involved providers who are significantly more prepared for ICD-10 than many of their peers, physician groups fear that the acceptance rate could actually be much worse after the Oct. 1 implementation.

As a result, the groups strongly urged CMS to release more detailed end-to-end testing results broken out by the type and size of providers who tested, number of claims tested by each submitter, percentage of claims successfully processed, and specific details about problems encountered.

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