Nearly 100 physician groups representing state and specialty medical societies have written a letter to the Centers for Medicare & Medicaid Services (CMS) regarding ICD-10 concerns that the groups say the agency has not addressed.
In the letter to CMS Acting Administrator Andrew Slavitt, the physician groups, led by the American Medical Association (AMA), claimed that there remains a lack of industry-wide, thorough end-to-end testing of ICD-10 in administrative transactions. The write, “CMS conducted acknowledgement testing of claims for one week in March and November 2014 and additional weeks are planned in March and June 2015. Acknowledgement testing, however, is limited in that it only tests that the claim will be initially accepted through the claims processing system. It provides no information about if and how the claim will process completely, ensuring payment to physicians.”
The groups also didn’t seem too impressed by the recently released end-to-end testing results, which revealed an 81 percent acceptance rate. “In comparison, the normal acceptance rate for Medicare claims is 95-98 percent. Given that Medicare processes 4.4 million claims per day, even a small change in this acceptance rate will have an enormous impact on the system and payment to physicians,” they said, asking the agency to explain in detail the errors that were encountered and what steps need to be taken to correct these problems.
CMS is only planning on testing with 850 claims submitters per testing week for a total of 2,550 testers, representing a very small fraction of all Medicare providers and an even smaller universe of claims submitted each year, the groups attested. “We strongly urge CMS to release more detailed end-to-end testing results broken out by the type and size of providers who tested, number of claims tested by each submitter, percentage of claims successfully processed, and specific details about problems encountered,” they said.
In addition to claim processing, questions remain about the ability to correctly collect and calculate quality data during and after the transition to ICD-10, the groups wrote, as they foresee unintended consequences for measure denominators and measure rates due to potentially conflicting timelines with the physician quality reporting system (PQRS) and meaningful use quality reporting periods. Specifically, they ask CMS to provide details on how it plans to ensure that the measure calculations for these programs are not adversely impacted by the transition to ICD-10.
The groups fear that contingency plans may be inadequate if serious disruptions occur on or after Oct. 1. “Physicians are being asked to assume this significant change at the same time they are being required to adopt new technology, re-engineer workflow, and reform the way they deliver care—all of which are challenging their ability to care for patients and make investments to improve quality,” they wrote.
