House and Senate passage of legislation delaying the ICD-10 implementation deadline by one year to October 2015 is proof that the Centers for Medicare and Medicaid Services' approach to the code switchover is flawed and CMS must "reset" the process, argues Robert Tennant, senior policy advisor at the Medical Group Management Association.
"We believe that this is recognition that physician practices and others were facing a monumental challenge in meeting the October 1, 2014 deadline for ICD-10," Tennant told Health Data Management. "I think Congress did the right thing by recognizing that well in advance and allowing CMS to reset the process."
Representing more than 33,000 medical practice administrators and executives, MGMA has a big stake in seeing the ICD-10 deadline extended. In January, the organization released results of a survey that found that less than 10 percent of 570 responding practices reported making significant progress in overall ICD-10 readiness. MGMA's concern is that practices unable to code in ICD-10 to bill for services and procedures would not have their claims processed, leading to cash flow interruptions, additional costs and delayed claims payments.
"The reality of our country is you can't just grind healthcare to a halt to get better diagnosis codes," said Tennant. "If there was a catastrophic cash-flow disruption--which many experts surmise would happen if the [October 1, 2014] date was kept--there could be a dramatic impact not just on cash flow for practices but even their ability to stay open. And, all to get more granular diagnosis codes."
Last month, CMS offered ICD-10 acknowledgement testing to allow providers, billing companies, and clearinghouses the opportunity to determine whether CMS will be able to accept their claims with ICD-10 codes. And, in a policy reversal, CMS announced in February that it would offer "end-to-end" ICD-10 testing for a "small sample group of providers" in late July. However, according to Tennant, the ICD-10 testing that CMS is offering is too little, too late.
"You can't go live and then cross your fingers and hope claims are paid. That's not how healthcare should work," he said. "Any kind of major transition requires tremendous amounts of testing. The fact is that CMS wasn't even going to do any testing until MGMA and others crowed very loudly about this and complained. Finally, they relented and agreed to do front-end testing, which just occurred in March. Then, MGMA again had to complain and they reluctantly agreed to do end-to-end testing with a limited number of providers, but not until late July. Well, that's not enough time and it's not broad enough to help the industry."
At a minimum, now that the ICD-10 deadline has been extended by one year, CMS should "open up their testing doors to any provider who wants to test with them," Tennant asserts. If we can't move ahead with these types of transitions, then maybe we need to look at what the process is and change the way we do things. And, so, we're going to be strongly advocating for CMS to take a very different approach to these types of mandates because clearly the approach they're taking is not working."
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