The delay of ICD-10 implementation may offer industry stakeholders an opportunity to ensure "good to go," if not perfect, functionality–or may enable dawdlers to squander the extra time, a panel of experts said June 10 before the standards subcommittee of the National Committee on Vital and Health Statistics.

"We have the opportunity, over the next 18 months, to robustly test all of the documentation, coding methodologies, practice management systems, interfaces and adjudication systems affected by this change," said Holly Louie, chair of the ICD-10 CM Committee of the Healthcare Billing and Management Association. "In other words, we can have 18 months of end-to-end testing. Unfortunately, the extremely disappointing response from CMS that they would delay this necessary testing until 2015 completely squanders that opportunity.

“Following CMS’ lead, some commercial payors have already announced that they will delay robust testing with trading partners, which should be well underway, until the summer of 2015. It certainly begs the question: Were all who represented they were ready for the October 1, 2014 changeover, truly ready?"

Louie noted that an HBMA member survey conducted in May found only a very small number had conducted any full end-to-end testing. Of the testing that was possible, which included the Medicare contractor high-level, syntax-only testing in March, Louie said 38 percent reported it was unsuccessful.

"That is a very different finding than the CMS notice published on May 30 that stated contractors accepted 89 percent of the test claims and therefore testing was successful," she testified.

Louie said HBMA strongly recommends national testing schedules beginning now and continuing through September, 2015.

"Testing must accurately represent a live claim environment and must include the adjudication and 835 response," she said. "Furthermore, all local and national coverage decisions that will be active on October 1, 2015 should be published and available as future policies."

Sue Bowman, senior director of coding policy and compliance for the American Health Information Management Association, also stressed that a further lag in implementation road map could be prohibitively costly.  

"Until the interim final rule establishing October 1, 2015, as the new compliance date is published, uncertainty regarding the transition date will continue to persist," Bowman said. "And even after this rule is issued, we believe that many stakeholders will still not move forward with ICD-10 preparation and implementation activities because they will likely expect the compliance date to be delayed again next year. Any ICD-10 delay is disruptive and costly for healthcare delivery innovation, payment reform, public health, and healthcare spending."

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