The American Hospital Association also has concerns about this policy, although the AHA doesn't believe it has been finalized yet, association officials told InformationWeek Healthcare.
MGMA's letter said that it is "extremely concerned with the Medicare announcement that it will not be conducting ICD-10 end-to-end testing with external trading partners, including physician practices … This action would increase the potential of a catastrophic backlog of Medicare claims following the Oct. 1, 2014 compliance date. Failure to [test] could result in significant cash flow disruption for physicians and their practices, and serious access to care issues for Medicare patients."
[ Struggling with an electronic healthcare record system? Read Why Some Doctors Don't Lean On EHR. ]
Noting the extremely complicated nature of the transition to the ICD-10 diagnostic code set, MGMA said, "End-to-end testing between trading partners is absolutely critical to measure operational predictability and readiness, and also to identify any roadblocks well in advance of the compliance date."
Moreover, the association said, commercial health plans tend to take their lead from Medicare. If Medicare decides that end-to-end testing is unnecessary, many of these private insurers will also decline to do testing. "Again, this could result in practitioners not being paid for their services and disruption to healthcare service delivery," the letter said.
MGMA cited several inconsistencies between this decision and other policies of the Centers for Medicare and Medicaid Services (CMS):
-- Medicare conducted end-to-end testing with providers for the industry-wide transition from the HIPAA 4010 transaction set to the 5010 set well in advance of the compliance date.
-- Last fall, CMS contracted with National Government Services (NGS), a Medicare contractor, to develop a checklist for testing of ICD-10 and other standards required by the government. NGS recommended that providers test ICD-10 with Medicare.
-- CMS is requiring all state Medicaid agencies to test with their external trading partners, including providers.