ICD-10; Ready or Not Here it Comes

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March 4, 2015 by Lisa Brammer

The compliance deadline for health care providers, health plans, and health care clearinghouses to transition to ICD-10 is October 1, 2015. The implementation of ICD-10 brings with it a host of emotions: anger, anxiety, and denial are just a few. The original launch date of ICD-10 was slated to take place in 2011. The “false alarm” start dates since have made it kind of reminiscent of Aesop’s fable, “The Boy Who Called Wolf.” But, after last month’s (February 11th) hearing, “Examining ICD-10 Implementation“ conducted by the Energy and Commerce Subcommittee on Health, it appears as if it will be out with the old ICD-9 and in with (I won’t say new) ICD-10 on October 1, 2015.

Are you ready?

Many proponents of the October 1, 2015 transition say that the almost 40 year old ICD-9 is antiquated and the expanded ICD-10 is an important part of bringing our healthcare system into the 21st century. They are ready and have been, delaying will only cost them more.

Opponents, like the American Medical Association (AMA) remain concerned about costs and impacts of the codes. The AMA has considered ICD-10 to be a massive unfunded mandate that comes at a time when physicians are trying to meet several other federal technology requirements and risk penalties if they fail to do so.

Before the February 11th hearing, the Government Accountability Office was asked to conduct a study on the readiness of the Center for Medicare and Medicaid (CMS) and the transition to ICD-10. Their report confirmed that CMS was prepared, but there are concerns that CMS cannot handle this huge undertaking.

Dr. Michael C Burgess, an obstetrician/gynecologist from Texas, spoke at the Energy and Commerce Subcommittee on Health hearing. “All roads eventually lead to CMS,” he said. “And if you will pardon me, that does appear to be a weak link in the chain….When CMS flips the switch, something breaks. Any time they flip a switch that involves the processing of data, their systems fail.” Dr. Burgess went on to ask, “What is the contingency plan for any problems that may develop?” He talked about how he asked about contingency plans before the launching of Healthcare.gov and was told that they were not necessary—no contingency plan was needed for the October 1st launch. “We know what happened after that,” Burgess said.

Unfortunately, it appears as if contingency planning is being left to the providers who are encouraged to have enough money on hand to cover themselves when cash flow diminishes due to delayed or denied claims. CMS estimates that the early stages of ICD-10 implementation will see denial rates rise by 100-200% and days in A/R could grow by 20-40%.

CMS has been conducting both acknowledgement and end-to-end testing to help ensure readiness. While ICD-10 acknowledgment testing is available any day of the year up to October 1, 2015, CMS is hosting a dedicated opportunity for providers this week, March 2 – 6, 2015.

Acknowledgment testing is a way to determine if a claim can be accepted by a Medicare Administrative Contractor for settlement. This type of testing will only let you know if the sample claim can be accepted for processing. It is not the same as end-to-end testing, which processes a claim through all Medicare systems to produce an electronic remittance advice.

If you are not sure what type of testing you are eligible to participate in MLN Matters® Special Edition Article SE1501 explains the differences between acknowledgement and end-to-end testing with Medicare.

CMS has a website to help providers with their action plan. I’m sure you’ve heard of it, Road to 10. There are only 210 days left until October 1st. Will you be ready?

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