The American Hospital Association (AHA) has sent a letter encouraging CMS to expedite their ICD-10 testing plans to ensure testing begins no later than January 2014 and is made available to all hospitals. Despite CMS offering extensive ICD-10 educational opportunities, the AHA states that “extensive, end-to-end testing by Medicare contractors and state Medicaid agencies of both the electronic transaction and the adjudication of the claim will be needed to ensure a smooth transition from ICD-9 to ICD-10.”
In the letter addressed to CMS Deputy Administrator and Director, Jonathan Plum, states, “testing is not only essential to ensuring that the transition to ICD-10 goes as smoothly as possible, it is a legal requirement under Section 1104 of the Patient Protection and Affordable Care Act (ACA). Specifically, the ACA requires all health plans (including Medicare and Medicaid) to certify that they are in compliance with all HIPAA transaction standards and operating rules, including ICD-10.
The ACA goes on to state that a health plan “shall not be certified as being in compliance with such standards, unless the health plan … provides documentation showing that the plan has completed end-to-end testing for such transactions with their partners, such as hospitals and physicians,” said Linda Fishman, AHA senior vice president of public policy analysis and development.
Importance of Early ICD-10 Testing
According to the letter, all ICD-10 testing should be completed by the end of June 2014 for:
- providers, payers and clearinghouses to resolve any issues discovered during ICD-10 testing
- complete training well in advance of the Oct. 1, 2014 transition date
Essential Components of ICD-10 Testing
Most hospitals are already targeting January through June 2014 to conduct external ICD-10 testing with their partners. The AHA also identified two essential components for successful ICD-10 testing:
- Testing connectivity and the transaction exchange for a claim containing ICD-10 codes.
- Testing the provider’s and payer’s ability to correctly handle the ICD-10 content as part of the claims adjudication process.
Additionally, hospitals should be provided with clear instructions on how to register for testing including an established “go-live” date for ICD-10 testing for all Medicare contractors.
In 2011, the U.S. Department of Health and Human Services (HHS) estimated that the overall cost of ICD-10 transition would be $1.64 billion. This estimate includes:
- $357 million for staff training
- $572 million for losses in productivity
- $713 million for system changes
