The Medical Group Management Association is calling on the Centers for Medicare and Medicaid Services to significantly increase its testing of ICD-10 during 2014.
A single front-end testing week for Medicare during March 2014 is simply insufficient, MGMA tells Health and Human Services Secretary Kathleen Sebelius in a letter sent on December 9. MGMA also asks that Medicare start full end-to-end testing as soon as possible. The agency has not yet committed to end-to-end testing and the association fears commercial insurers will follow suit and not test as they often follow Medicares direction on operational issues.
As the industry saw with the move to HIPAA Version 5010, failure to identify issues well before the compliance date will lead directly to a protracted industry implementation and significant disruption of cash flow for a large number of physician practices, the association tells Sebelius. With HIPAA Version 5010, more testing and better dissemination of the testing results could have averted many of the problems that practices, clearinghouses, health plans and software vendors experienced prior to and immediately after their go-live dates. Consequently, MGMA urges Sebelius to order Medicare contractors and state Medicaid agencies to conduct end-to-end testing of ICD-10.
In its letter to Sebelius, the Medical Group Management Association also offers nine actions that CMS can take to ease transition to the new coding set:
* Expand the current Medicare front-end testing week in March to permit complete end-to-end testing with any willing physician practice. The tests should include return of remittance advice so practices can see how ICD-10 will affect their reimbursement rates. If you are unable to provide testing services for all willing providers, we urge you to conduct end-to-end testing with a sufficient number and breadth of specialties to facilitate the identification of the most common claim adjudication issues.
* While testing with Medicare should be permitted throughout the year, expanding the national testing weeks to a minimum of one per quarter would increase industry awareness of the need for testing.
* Disseminate results of Medicare testing as soon as possible after a testing period.
* Expedite release of Local Coverage Determinations and all other Medicare claim transaction edits associated with ICD-10.
* Disseminate ICD-10 readiness status of all Medicare contractors and state Medicaid agencies each month.
* Work with industry partners to determine the readiness level of commercial health plans, particularly to handle Medicare secondary and cross-over claims that move from Medicare to commercial plans or vice-versa.
* Expand CMS provider education on specialty-specific coding and clinical document improvement.
* Expand CMS outreach to practice management and electronic health record vendors to determine their readiness.
* Implement advance payments for Medicare and Medicaid-credentialed providers requesting them. This would be a critical component of a national contingency plan should provider reimbursements be negatively impacted after Oct. 1, 2014.
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