Rep. Diane Black (R-Tenn.) has introduced legislation requiring Medicare to conduct a comprehensive, end-to-end ICD-10 testing process to assess whether the Medicare fee-for-service claims processing system is fully functioning using the new code set.

H.R. 2247, the Increasing Clarity for Doctors by Transitioning Effectively Now (ICD-TEN) Act, calls for end-to-end testing process to be available to all providers of services and suppliers participating in the Medicare fee-for-service program under parts A and B. Further, the proposed legislation seeks to institute an 18-month transition period beginning with the October 1, 2015 ICD-10 implementation deadline, during which no claim submitted for payment by a provider would be denied as a result of using an unspecified or inaccurate code.

“This legislation is critical to increasing transparency in the testing process and allowing providers sufficient time to adapt to the new, significantly more complex coding system without suffering delays in reimbursement,” said Black. “The Administration claims that all testing is going according to plan, but we have heard this line before. Prior to the October 1, 2013 launch date, Congress and the American people were repeatedly assured that was ready for primetime, only to learn that the website was riddled with flaws, some of which have still not been fully addressed. Our healthcare providers and their patients cannot afford another October technical surprise this fall. We must ensure that a solid transition is in place prior to implementation of the new ICD-10 system.”

The American Health Information Management Association opposes Black’s bill arguing that an 18-month transition period for ICD-10 should not serve as a reason for providers to delay properly learning to use the new code set and generating accurate codes supported by high-quality clinical documentation, nor to reduce the effectiveness of audits in curtailing fraud and abuse.

“While the bill calls for CMS to conduct mandatory end-to-end testing and certify that Medicare systems are functioning, the fact is that this is unnecessary,” according to AHIMA. “CMS has already been conducting end-to-end testing for some time. After the first Medicare fee-for-service end-to-end testing in January, CMS reported that only three percent of rejected claims were due to invalid submission of an ICD-10 code. Other claims were rejected because of errors unrelated to ICD-10. In addition, providers, suppliers, billing companies and clearinghouses can submit test claims to Medicare any time up to the October 1 implementation date.”

Also See: CMS Touts Success of ICD-10 End-to-End Testing

As a result, AHIMA asserts that significant payment disruptions for physician practices are unlikely, pointing to a recent report by the Government Accountability Office which found that CMS has done ample outreach and preparation to help the industry prepare for the code switchover from ICD-9 to ICD-10.

“Testing has demonstrated that CMS systems are ready to accept and process ICD-10 claims,” states the organization. “To further mitigate this risk, AHIMA recommends that CMS grant ‘advance payments’ to any physicians that do experience cash flow disruptions as a result of the ICD-10 transition.”

In related news, Rep. Ted Poe (R-Tex.) has introduced H.R. 2126, the Cutting Costly Codes Act of 2015, which seeks to outright prohibit the Secretary of the Department of Health and Human Services from replacing ICD-9 with ICD-10. The American Medical Association in a May 14 letter to Poe voiced its “strong support” for the bill.

“The differences between ICD-9 and ICD-10 are substantial, and physicians are overwhelmed with the prospect of the tremendous administrative and financial burdens of transitioning to ICD-10,” wrote James L. Madara, M.D., executive vice president and CEO of the AMA, in his letter to Poe. “The timing of the ICD-10 transition could not be worse as many physicians are currently spending significant time and resources implementing electronic health records into their practices and adopting new payment and delivery models.”

Madara told the congressman that AMA believes the bill “takes the prudent approach to set aside the implementation of ICD-10 and seek solutions that mitigate the disruption to physician practices when advancing to a new diagnostic code set.”

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