The Workgroup for Electronic Data Interchange has called on the Department of Health and Human Services to adopt the organization's proposed ICD-10 transition roadmap in order to "minimize continued disruption to the healthcare industry" as a result of the one-year ICD-10 delay.
The high-level roadmap is based on stakeholder feedback gathered at WEDIs April 30 emergency ICD-10 Summit. In a letter to outgoing HHS Secretary Kathleen Sebelius, WEDI recommends that HHS take immediate steps including: ensuring Medicare and Medicaid readiness transparency; expediting, supporting and expanding industry testing; expanding provider education and support; targeting outreach to non-covered entities such as workers compensation plans; conducting or supporting limited pilots; and establishing clear ICD-10 milestones and tracking readiness.
"We are concerned that if the implementation actions continue as is with the new compliance date, the industry could experience ongoing challenges leading to protracted implementation and unnecessary burden and cost," writes Jim Daley, chairman of WEDI, in the letter to Sebelius. "We applaud steps already taken, but recognize there is still more that can and should be done."
HHS expects to release an interim final rule in the near future that will include a new compliance date requiring the use of ICD-10 beginning October 1, 2015. The rule will require HIPAA covered entities to continue to use ICD-9-CM through September 30, 2015.
Last week, the Centers for Medicare and Medicaid Services announced that the partial code freeze for ICD-9-CM and ICD-10 will continue through October 1, 2015. And, last month, CMS canceled limited end-to-end testing that had been scheduled for late July, when a small sample group of providers were to have been given the opportunity to participate in end-to-end testing with Medicare Administrative Contractors and the Common Electronic Data Interchange contractor.
"We believe the canceling of the limited July 'end-to-end' testing sent the wrong message to the industry. Rather than delay this critical form of testing until 2015, we recommend expediting and expanding this form of trading partner testing," states Daley.
ICD-10 acknowledgement test claims can be submitted anytime up to the new planned October 1, 2015 ICD-10 implementation date. However, CMS is advising stakeholders to delay this front-end testing until after October 6, 2014, when Medicare is scheduled to update its systems.
Medicare and Medicaid ICD-10 readiness transparency is a high priority, according to WEDI. "CMS could instill greater confidence by offering early evidence that Medicare and Medicaid are fully prepared for ICD-10 and by conducting/supporting more extensive industry testing," states the letter to HHS. "We encourage Medicare and Medicaid to publicly disclose all ICD-10 related readiness levels and expected testing timeframes. Sharing of new edits or revised medical policies due to ICD-10 would help trading partners understand what may or may not be changing and will assist them in determining where to place emphasis during testing."
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