Hot off the Press: No ICD-10 End-to-End Testing by CMS

“OMG” is about the best way to not only get your attention as a reader of this article, but my first thought as I reflect on the breaking news from the HIMSS ICD-10 Leadership Forum in National Harbor, Maryland this week.  Definitely the biggest “take away” is the announcement from CMS that they will not do ICD-10 end-to-end testing with the providers!  WHAT?   Yes, you heard correctly, and for those of us close to ICD-10 and who understand the ramifications of this wonder: what kind of message is this sending to our providers?

With a background in revenue cycle, I gasped at this announcement, as the industry always takes the lead from our very own CMS!  “Here we go again” is all I can say.  So, my best advice to providers is “change your mindset!”  End-to-end testing will be extremely important to you and your organization as you approach October 1, 2014.  It will be imperative to understand your revenue cycle and assure that clean claims go out the door, right the first time! The goal for every organization is to assure that you obtain the reimbursement you are entitled to, and the way to achieve that goal is to perform end-to-end testing of your claims data.  Please know that you have control over your destiny and success with ICD-10 implementation!

We attendees of the ICD-10 Forum first heard this from Mark Lott, CEO at Lott QA Group, who represented HIMSS and Wedi in his presentation, but it was the affirmation from Denise Buenning, Deputy Director, Office of E-Health Standards and Services at Centers for Medicare & Medicaid Services,   on day two (2) of the forum that made most of us want to ask “why?”   I at first held back with the “why” question but someone had to ask!  I asked Denise about the ramifications of this decision from CMS, noting that she is just the messenger and did not make this decision.  She responded that “providers need to do testing regardless; just because CMS is not going to do end-to-end testing with them.”   Whew was my reaction, knowing that the many followers of CMS need to hear this message loud and clear because many will only hear the later!

My concern in general is that a large part of the industry should be doing end-to-end testing NOW, when in reality maybe 50% of the industry is in this stage of implementation.  End-to-end testing takes time, at least a good year as a benchmark, in order to do it right. With a little more than 450 days left until implementation date, it begs the question, “what about the other half of the industry?”  I have visions of unpaid claims, rejections, and denials, to name a few issues, come October 1, 2014.   

This announcement has started buzz among the HIMSS Forum attendees as they try to understand the rationale behind the decision.  Is it lack of manpower or is it because there is a lack of understanding of end-to-end testing?  As I thought about Ms. Buenning’s presentation, I could not help but try to interpret her closing statement.  At the end of her presentation she emphasized that when October 1, 2014 arrives, CMS wants to assure that the “providers reimbursements continue to flow.” This statement sounds contradictory, since CMS has chosen not to perform end-to-end testing with providers.  As I ponder over this, I can only assume or predict that CMS will “open the gates” for all claims to assure that “provider’s reimbursements continue to flow.”  Please note that this is strictly my opinion and that there are payers other than Medicare to worry about come October 1, 2014.  Oh, and don’t forget that third party auditors will be watching. Stay tuned because this is just the beginning of many conversations and articles to come regarding the implications of CMS not performing ICD-10 end-to-end testing with providers!   

Published Date: 

Wednesday, June 19, 2013