Robert Tennant, MGMA's senior policy advisor, told InformationWeek Healthcare that CMS officials confirmed Medicare's non-testing policy at a meeting of the National Committee on Vital Health Statistics (NCVHS). An agency official also referred to it July 15 at a "listening session" that included representatives of key stakeholders, he said. But CMS never announced the decision publicly, and it declined an InformationWeek request for comment on the MGMA letter.
Speaking at the NCVHS meeting, CMS official Denise Beunning explained that the decision not to test was "a business decision that Medicare fee for service has made." Based on the internal testing that the Medicare division has done, she said, "They feel that is going to be adequate for them to process claims with ICD-10 and have them go through the system smoothly."
Nevertheless, she added that after receiving feedback from NCVHS' standards subcommittee, "I think they [Medicare officials] left here with the intention of perhaps … having some discussions among themselves as to whether it would be prudent to conduct end-to-end testing with providers, and if so, what that might look like. I think that based on industry feedback and feedback from the subcommittee, that they are now open to that discussion."
Tennant said he hadn't yet received any official CMS response to the MGMA letter, other than that it was being circulated in the agency. "Their argument is that they're focused on internal readiness and that should be sufficient," he said. In addition, he noted, the agency believes that because Medicare contractors can accept 5010 claims transactions and most providers are now using 5010, "there should be no problem with ICD-10. We don't share that opinion."
MGMA wants Medicare contractors to test ICD-10 claims submission with a subset of both providers and electronic clearinghouses. If that is done, Tennant said, "They can identify problems and disseminate that information out the industry. That's really the goal, so providers know where the potential pitfalls and problems are and can correct them prior to the compliance date."
The majority of MGMA members submit Medicare claims through clearinghouses, Tennant observed. But clearinghouses can't fix ICD-10 claims the way they solved problems with 5010 transactions. For example, he noted, "they can't arbitrarily assign an ICD-10 code to a claim and convert a ICD-9 code to an ICD-10 code without having more information from the practice, which can be problematic."
AHA officials said they still weren't sure whether CMS had finalized its decision on testing. George Arges, senior director of AHA's health data management group, said that he'd been told CMS would make an announcement about this in the near future, probably in September.
Added Chantal Worzala, the association's director of policy, "AHA has voiced concern with CMS that hospitals need the ICD-10 testing to be adequate. We are still working with CMS to fully understand the extent of testing that they plan to do. Our opinion is that the minimum necessary is testing that will allow hospitals and Medicare contractors to validate DRG assignments."