The American Hospital Association (AHA) is urging the Centers for Medicare & Medicaid Services (CMS) to expedite its ICD-10 testing plans to make sure testing begins no later than January 2014 and that it is made available to all hospitals.
In a letter to CMS sent on November 20, AHA says that while it appreciates the agency’s efforts to offer extensive educational opportunities for providers, 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.
Hospitals across the country have invested significant financial and human resources in preparing for the transition to ICD-10 that will occur on Oct. 1, 2014. AHA says that its members have said that they are ready, or nearly ready, to start external testing with CMS and others. “Therefore, we were concerned to read recent news articles stating that the agency would not undertake external testing of ICD-10 due to a lack of funding within the agency, according to a CMS official,” wrote Linda Fishman, AHA senior vice president of public policy analysis and development.
As CMS rolls out external testing, AHA asks the agency to allow for and provide the same opportunity for small hospitals to test with its contractors as larger facilities, citing concerns that these providers will be overlooked.
According to AHA, successful testing requires two essential components:
Testing connectivity and the transaction exchange for a claim containing ICD-10 codes. Since the current 5010 transaction standard will be used to transmit the ICD-10 codes, AHA does not expect connectivity problems arising from the claims data exchange. Nevertheless, this testing step still needs to be done to ensure that any changes made to accommodate the ICD-10 codes in the 5010 standard did not create exchange problems. The connectivity test also should include plans for front-end edit testing of the claim to ensure that it can pass an initial review of claim integrity and then move forward to the next level—the claims adjudication process.
Testing the provider’s and payer’s ability to correctly handle the ICD-10 content as part of the claims adjudication process. The test of the claims adjudication process should help providers understand whether there is a match between the anticipated payment and the payment actually assigned by the health plan. This step will allow hospitals to identify and correct any errors in their documentation and coding processes. It will also provide them with needed information to estimate how the transition might affect revenues.