On Tuesday, four republican senators sent a letter to CMS expressing concerns regarding the limited “brevity and scope” of front end ICD-10 testing scheduled for the week of March 3, 2014. The letter sent to CMS Administrator Marilyn Tavenner warned, “before either Medicare or Medicaid could conceivably transition to any new diagnostic coding method, CMS must establish clear metrics and perform system-wide tests to certify its readiness.”
10 Questions for CMS
The letter was signed by Senators John Barrasso (R-Wyo.), John Boozman (R-Ark.), Tom Coburn (R-Okla.) and Rand Paul (R-Ky.) asked Tavenner to answer the following ten questions by 2/26:
1. What metrics will CMS use to evaluate the success of the ICD-10 testing period in March? What are the targets CMS has set for each of these metrics to determine whether the testing period was successful?
2. Will the testing period allow Medicare providers to test accurate and prompt claim adjudication? If not, does CMS plan on executing more testing periods before full implementation (currently scheduled for October 1, 2014) to ensure claims can be accurately submitted and paid under ICD-10?
3. Before full implementation, does CMS plan to test the appeal process for claims submitted due to incorrect ICD-10 codes as providers and staff transition to the new system?
4. When does CMS plan to release results from the testing period to the public, so that providers and other entities may make necessary changes to their systems?
5. How will CMS measure the ICD-10 readiness of Medicare Administrative Contractors (MAC) and state Medicaid agencies before full implementation? Will CMS require MACs and Medicaid to demonstrate successful end-to-end testing before all providers have to switch to ICD-10? What is the current ICD-10 readiness of these entities?
6. Provide a list of any internal or third-party testing CMS has scheduled before full implementation of the ICD-10 coding system.
7. Will CMS perform full testing of Recovery Audit Contractors (RAC), the Fraud Prevention System (FPS), and other anti-fraud efforts to ensure full capability to perform anti-fraud investigations? If so, what metrics and targets will CMS use to ensure ICD-10 readiness of RACs and the FPS?
8. When will CMS release a crosswalk of Local Coverage Determinations and all other Medicare claim transaction edits associated with ICD-10 codes?
9. How often has CMS studied the ICD-10 readiness of the providers and other third parties? What industry analyses or surveys is CMS relying on for information on the ICD-10 readiness of providers and other third parties?
10. Has studied CMS the impact the ICD-10 transition may have on upcoding? Describe the results of any findings.
CMS Announces End to End ICD-10 Testing This Summer
CMS announced late Wedesday, that CMS will conduct end to end ICD-10 testing with a limited number of providers this summer (Medpage, 2/19/14). In the announcement, CMS stated, “The small sample group of providers who participate in end-to-end testing will be selected to represent a broad cross-section of provider types, claims types, and submitter types.”
CMS will provide further details about testing at a later date.
According to the recent updated AMA report, the cost of the ICD-10 transition can range between $83,290 for small practices and $2.7 million for large physicians practices.