CMS Agrees to Expand ICD-10 Testing

In the wake of the disaster that was the launch of Healthcare.gov, the Centers for Medicare and Medicaid Services will allow limited end-to-end testing of Medicare claims filed under ICD-10 codes, the agency announced last week.

Healthcare providers must switch to the ICD-10 coding standard by Oct. 1, 2014. For months CMS had stated that the only testing it planned to do was “ ”front-end ICD-10 testing between MACs and their trading partners.” Those limited tests will run  next week from March 3 to March 7. However, shortly after the botched launch of Healthcare.gov, CMS began to slowly backpedal, announcing it was examining the possibility of end-to-end testing.

On Feb. 19 CMS reversed its earlier position and announced it would schedule end-to-end testing for sometime this summer.

The decision comes on the heels of a letter sent by four U.S. Senators, all physicians, expressing concern about the lack of end-of-end testing. “The brevity and limited scope of this test is worrisome,” Senators Tom Coburn (R-Okla.), John Barrasso (R-Wyo.), John Boozman (R-Ark.), and Rand Paul (R-Ky.) wrote. “This change will impact millions of physicians and patients, and hundreds of billions of dollars in payments that flow through Medicare and Medicaid. Other major federal IT projects—such as the implementation of Healthcare.gove—have demonstrated the importance of thorough pre-testing …”

The doctor-legislators are not fans of ICD-10, having earlier filed a bill to halt migration to the new coding standard.

Providers should not expect extensive end-to-end testing. CMS has stated the tests will be conducted involving a small subset of providers.

Next week’s testing, by comparison, “will allow all providers, billing companies, and clearinghouses the opportunity to determine whether CMS will be able to accept their claims with ICD-10 codes,” according to a CMS release. “While test claims will not be adjudicated, the MACs will return an acknowledgment to the submitter (a 277A) that confirms whether the submitted test claims were accepted or rejected.”

Below is CMS’s statement regarding the upcoming end-to-end testing:

End-to-End Testing

In summer 2014, CMS will offer end-to-end testing to a small sample group of providers. Details about the end-to-end testing process will be disseminated at a later date.

End-to-end testing includes the submission of test claims to CMS with ICD-10 codes and the provider’s receipt of a Remittance Advice (RA) that explains the adjudication of the claims. The goal of this testing is to demonstrate that:

• Providers or submitters are able to successfully submit claims containing ICD-10 codes to the Medicare FFS claims systems;
• CMS software changes made to support ICD-10 result in appropriately adjudicated claims (based on the pricing data used for testing purposes); and
•  Accurate RAs are produced.

The small sample group of providers who participate in end-to-end testing will be selected to represent a broad cross-section of provider types, claims types, and submitter types.

If you have any questions, please contact your MAC at their toll-free number, which may be found at http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare- FFS-Compliance-Programs/Review-Contractor-Directory-Interactive-Map/index.html on the CMS website.