“OMG” is about the best way to sum up my first thoughts as I started reflecting on the breaking news from the HIMSS ICD-10 Leadership Forum in Fort Washington, Md. this week.
Definitely the biggest takeaway was the announcement from the Centers for Medicare & Medicaid Services (CMS) that it will not perform ICD-10 end-to-end testing with providers. Yes, you read that correctly, and those of us close to ICD-10, who understand the ramifications of this, now wonder: what kind of message is this sending to providers?
With a background in revenue cycle, I literally gasped at this announcement, being as the healthcare industry always takes its leads from CMS. “Here we go again” was all I could say. So my best advice to providers is this: change your mindset! End-to-end testing will be extremely important to you and your organization as you approach the ICD-10 implementation deadline of Oct. 1, 2014. It will be imperative to understand your revenue cycle and ensure that clean claims go out the door right the first time. A key goal for every organization should be to ensure that you obtain the reimbursement to which you are entitled, and one 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 ICD-10 implementation success!
We attendees of the forum first heard this from Mark Lott, CEO of Lott QA Group, who represented HIMSS and WEDI in his presentation, but it was the affirmation from Denise Buenning, deputy director of the CMS Office of E-Health Standards and Services, on day two of the forum that made most of us want to ask “why?” At first I held back, 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 the decision. She responded that “providers need to do testing regardless; just because CMS is not going to do end-to-end testing with them (doesn’t mean they shouldn’t do it).”
“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 first part!
My concern in general is that a large part of the industry should be doing end-to-end testing now, yet in reality maybe 50 percent of the industry has reached this stage. End-to-end testing takes time, at least a solid year as a benchmark, in order to do it right. With a little more than 450 days left until the 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 Oct. 1, 2014.
This announcement obviously generated a serious buzz among the forum attendees as they tried 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 Buenning’s presentation, I could not help but try to interpret her closing statement. In it she emphasized that when the implementation date arrives, CMS wants to ensure that the “provider reimbursements continue to flow.”
In retrospect this statement sounds contradictory, since CMS has chosen not to perform end-to-end testing with providers. And as I continue to ponder this, I only can assume or predict that CMS will open the gates for all claims to ensure that “provider reimbursements continue to flow.”
Please note that this is strictly my opinion, however, and that there are payers other than Medicare to worry about as we move forward. 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.
About the Author
Maria T. Bounos, RN, MPM, CPC-H, is the practice lead for coding and reimbursement software solutions for Wolters Kluwer. Maria began her career at Wolters Kluwer as a product manager, responsible for product development, maintenance, enhancements and business development and now solely focuses on business development. She has more than twenty years of experience in healthcare including nursing, coding, healthcare consulting, and software solutions.
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