Updated on: March 16, 2016

CMS Decision not to Engage in End-to-End Testing Presents ‘Dangerous Precedent’

Original story posted on: June 18, 2013

Much of the healthcare industry only discovered through announcements made during the HIMSS ICD-10 Leadership Forum this week that the Centers for Medicare & Medicaid Services (CMS) does not plan to engage in end-to-end testing – but Mark Lott, CEO of the Lott QA Group and testing director of the HIMSS WEDI ICD-10 National Pilot Program, said Wednesday that he first heard about it a couple of weeks ago.

Still, that extra time doesn’t mean he has drawn any closer to comprehending it.

Saying the decision “sets a dangerous precedent for everyone,” Lott echoed the confusion being expressed among providers nationwide in an exclusive interview with ICD10monitor this week.

“The whole industry is trying to figure out how to end-to-end test. It’s in the regulations,” Lott said. “And the pilots and the national testing programs already have shown … that it’s not that cumbersome, not that expensive.”

“So the main thing is, this sends a conflicting message when CMS comes out and says ‘We internally tested and we don’t need to end-to-end test,’” he added.  “Obviously, everybody’s disappointed in that decision.”

Lott and others fear that the announcement could discourage individual payers not to engage in end-to-end testing, potentially creating logistical issues for payers and providers alike.

“And every provider is extremely worried about their cash flow to begin with,” Lott said.

Speculation about why CMS is choosing not to engage in the testing is ubiquitous, with many suggesting that potential logistical issues are a key factor.

“Medicare doesn’t want to get inundated with 10,000 requests to end-to-end test,” Lott said.

Yet Lott reported that he and other leading figures with the national testing program will be sitting down with CMS representatives during the next several weeks in what Lott described as a hopefully “open discussion” regarding the decision.

Lott labeled himself cautiously optimistic, saying the matter presents a striking reminder of the interconnected nature of the industry.

“There’s no such thing as a disconnected healthcare event,” he said. “Healthcare has so many moving parts in the supply chain … all the coders have to be trained and understand the new (ICD-10) nomenclature, all of the vendors have to come together with their upgrades … and you need better documentation in order to code better.”

“We want to see that whole process work,” Lott said.

As CMS notes on its own website, Section 1104 of the Patient Protection and Affordable Care Act (PPACA) of 2009 requires health plans “to certify compliance that they have adequate documentation that they are compliant with standards and operating rules, and that they have completed end-to-end testing with their trading partners.”

To implement and fulfill what are known as the “administrative simplification” requirements of the act,, covered entities must perform many steps, the agency added, including “assessing their health information systems to determine how to accommodate the new … requirements, making changes and testing the changes to their internal systems, and testing their systems with external trading partners to ensure the continuous exchange of administrative information.”

In September 2012, CMS awarded National Government Services (NGS) a one-year contract to develop a process and methodology for end-to-end testing of the “administrative simplification” requirements based on industry feedback and participation, the agency reported on its website, noting that the process was expected to offer an industry-wide best practice for end-to-end testing that “lays the groundwork for a more efficient and less time-consuming method for healthcare provider testing of future standards, leading to more rapid adoption of the future standards.”

“While the goal is a process that can be used across all administrative simplification requirements, ICD-10 will be the test case used during the pilot,” the agency noted. “Industry participation is essential to this project, and industry (members) can participate by becoming an industry collaboration partner, providing feedback in industry webinar sessions, or as a volunteer to pilot the end-to-end testing process.”



Mark Spivey

Mark Spivey is a national correspondent for ICDmonitor.com who has been writing on numerous topics facing the nation’s healthcare system (and federal oversight of it) for five years.