CMS is adequately preparing for ICD-10 implementation to go ahead on October 1, 2015, according toa new report from the Government Accountability Office (GAO) published late last week. Both Medicare and Medicaid agencies have taken the appropriate steps to complete internal technical changes, conduct industry outreach, and provide transitional help to providers, the report states, despite lingering concerns over external testing with the larger healthcare community.
The report provides an overview of CMS activities related to the ICD-10 transition, which has been delayed several times over the past few years. The investigators found that CMS has completed its internal testing plan for fee-for-service reimbursements, provided technical help to state Medicaid organizations, all of which affirm their readiness to perform “critical” transitional activities, and worked to alert and prepare healthcare providers for the change.
CMS has also performed significant outreach activities in response to stakeholder concerns over engaging the nation’s providers, including the development of timelines and checklists, web-based seminars, in-person training, and collaborative meetings.
“As demonstrated by this report, the provider outreach and responsiveness to stakeholder concerns from CMS have kept the agency on track to upgrade to the next level of healthcare coding,” said Senate Finance Committee Chairman Orrin Hatch (R-Utah), in a public statement. “While additional testing will be needed to ensure its success, the transition to the new system will streamline the management of healthcare records and improve patient care. I will continue to keep a close eye on this issue but see no reason for any delay past the October deadline.”
But healthcare providers are not so sanguine about the lack of widespread testing in the industry. CMS will be conducting three separate weeks of end-to-end testing with a sample of 2550 organizations in 2015, but the relatively small scale of the external testing, as well as its proximity to the deadline, has some groups worried about what will happen if major flaws are uncovered.
“If there are testing failures in March that are significant, you only have until October to fix them,” Dr. Michael Lee, Director of Clinical Informatics for Atrius Health, told EHRintelligence. “That’s a pretty short amount of time. It’s been a recurring theme with our communications with CMS around bothmeaningful use and ICD-10 that the expectations for technology changes have underestimated the technical complexity and the true safe delivery of software.”
“Software cycles in real life are fairly long,” he added. “For us to absorb technical changes from our vendor, install them, test them, develop training documentation, deliver them in the community and do follow up, those are often nine-month cycles for us – especially for major changes. If you’re asking your vendor to make changes, the vendor cycle needs to be at least that long, too. Add those two together and you get 18 months. If you’re doing a test in March, six months before your final delivery, it doesn’t give you a lot of time to repair things.”
The GAO report points out that not all state Medicaid agencies have even started acknowledgement testing, a largely successful venture on the Medicare side, and adds that “at this time, it is not known what, if any, changes might be necessary based upon [Medicare’s] ongoing external testing activities.” And the scope of the report does not include the preparation of private payers, nor of provider organizations, only 65% of whom believe that they will be able to begin their end-to-end testing before the October 1 ICD-10 implementation date.
Nevertheless, 2015 may end up being the end of the line for ICD-10 opponents, especially as support builds in Congress as well as in groups such as the Coalition for ICD-10.
“Today’s report by the Government Accountability Office affirms widespread recognition across the health care industry that CMS is well-prepared to implement the US transition to ICD-10 on October 1, 2015, and that the Agency has undertaken extensive efforts to help the health care industry prepare,” the Coalition said in a statement of their own.
“Coalition members are working together and with CMS to ensure a smooth and successful transition for all health care stakeholders. Our members are engaging in significant efforts to identify and educate those in need of implementation assistance through payer-provider collaboratives, training and outreach initiatives, and programs to help coders continue to achieve complete and accurate coding. We welcome the GAO report and support its findings. The US is ready to move forward with ICD-10 with no further delays.”
