Updated on: March 17, 2016

CMS: Small Sample of ICD-10 Testing Scheduled for Summer

Original story posted on: March 11, 2014

Succumbing to industry pressure, the Centers for Medicare & Medicaid Services (CMS) today announced that the agency would offer end-to-end testing to what it described as a “small sample group” of providers this summer. Details are expected to follow.


The issue of whether CMS would conduct end-to-end testing has been a speculatively contentious issue with ICD-10 stakeholders who have long contended that the agency should not have abandoned its commitment to conduct end-to-end testing, as it did in June 2013. 


As recently as last week, the American Medical Association, in a letter to U.S. Health and Human Services (HHS) Secretary Kathleen Sebelius, urged HHS to conduct what the association described as “true” end-to-end testing—a reference to the agency’s announcement last November that it would set aside the week of March 3-7 as “ICD-10 Testing Week,” but involve only Medicare Administrative Contractors and the DME MAC Common Electronic Data Interchange (CEDI) contractor.

Provider response to the CMS announcement at the time was viewed as “tepid” in a story published by ICD10monitor on November 19, 2013.

“This is a positive step forward for CMS, Medicare, and the provider industry,” wrote industry consultant Stanley Nachimson in an email to ICD10monitor.  “It [the announcement] responds to the chorus of organizations calling for such testing from Medicare, and will provide a much better picture of Medicare’s ICD-10 readiness than the March testing week results.” Nachimson said he is looking forward to seeing the details and results of this effort.

Joining Nachimson in acknowledging the CMS decision posted today was Mark Lott, CEO and president of the Lott QA Group and director of the HIMSS WEDI ICD-10 National Pilot Program. Lott, who has long argued for end-to-end testing, questions the methodology as described by CMS in its announcement today.

“(This) is a good thing, that CMS has finally recognized that they need to show that their systems are ready instead of having us just accept their word for it,” said Lott, who went on to say that the decision appears to him to be “window dressing.”

“They are only going to test with a very small number of providers,” said Lott. “Their rationale that they rigorously test internally and that is good enough does not make sense in regards to testing, because they have no idea how good or bad the ICD-10 coding will be when we go live. The biggest problem we see in ICD-10 testing is that no one knows what the right coding answers are supposed to be in claim, and so both entities, the provider and health plan, are testing without expected results.”

In its MLN matters article, SE 1409, the agency said that among its goals was to “demonstrate (that) providers or submitters are able to successfully submit claims containing ICD-10 codes to the Medicare FFS claims systems.”



AMA Letter

CMS has released MLN Matters article SE1409, “Medicare Fee-for-Service (FFS) International Classification of Diseases, Tenth Edition (ICD-10) Testing Approach.”  

Chuck Buck

Chuck Buck is the publisher of ICD10monitor and is the executive producer and program host of Talk Ten Tuesdays.