Don't let ICD-10 be like HealthCare.gov
The Medical Group Management Association has written to Health and Human Services Secretary Kathleen Sebelius, urging HHS to mandate end-to-end testing for ICD-10, arguing that not doing so could lead to "catastrophic" cash flow disruption for practices.
While MGMA applauded the decision of the Centers for Medicare & Medicaid Services to change course and initiate ICD-10 testing, "the type of 'front end' testing to be conducted is simply insufficient," writes Susan L. Turney, MD, president and CEO of MGMA.
"We strongly urge that the agency undertake full end-to-end testing with physician practices as soon as possible," she added. "Failure to appropriately test ICD-10 could result in operational problems similar to what the Department experienced with the rollout of HealthCare.gov and will dramatically increase the potential of catastrophic cash flow disruption for practices following the Oct. 1, 2014 transition date."
[See also: Ready or not, ICD-10 is near.]
Complete end-to-end testing helps developers of practice management and electronic health record software ensure their technologies can be appropriately configured for physician practices, Turney argued. Moreover, it's necessary to help identify critical problems "well prior to the Oct.1, 2014 compliance date and permit trading partners to institute the appropriate modifications to systems and/or workflow."
Finally, she wrote, "end-to-end testing is the only practical method practices will have to accurately predict and respond to Medicare coding edits and fully understand the impact that ICD-10 will have on reimbursement."
With private payers typically taking direction on operation issues from Medicare, the agency's refusal to do end-to-end testing – anticipating, detecting and ironing out problems with physician practices in advance – it's likely that many of these commercial plans will also not test, Turney argued.
"As the industry saw with the move to HIPAA Version 5010, failure to identify issues well before the compliance date will lead directly to a protracted industry implementation and significant disruption of cash flow for a large number of physician practices," she wrote.