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Updated on: March 17, 2016

Concerns Raised Over One-Week of ICD-10 Testing by CMS

Original story posted on: November 14, 2013

The recent decision by the Centers for Medicare & Medicaid Services (CMS) to set aside the week of March 3-7, 2014 as ICD-10 Testing Week is raising concerns among healthcare industry experts.

Amid a flurry of rumors that CMS stakeholders were reconsidering the need for end-to-end testing, the agency issued a change request (CR) for public distribution on Nov. 6. In the CR, CMS instructs all Medicare Administrative Contractors (MACs), as well as the DME MAC Common Electronic Data Interchange (CEDI) contractor, to implement an “ICD-10 Testing Week” with trading partners for the aforementioned first week of March 2014.


“The ICD-10 testing week has been created to generate awareness and interest, and to instill confidence in the provider community that CMS and the MACs are ready and prepared for the ICD-10 implementation,” the CR states. “The concept of trading partner testing was originally designed to validate the trading partners’ ability to meet technical compliance and performance processing standards during the HIPAA 5010 implementation.”


By most published accounts, the industry’s transition from 4010 to 5010 was plagued by production issues, marking one of the reasons cited as to why CMS extended the compliance date for ICD-10 from October 2013 to Oct. 1, 2014.

“We considered the unanticipated issues that occurred with the upgrade to Version 5010, which was widely believed to be an easier transition than ICD-10,” Denesecia Green, senior health insurance specialist with CMS, told listeners during a “Talk-Ten-Tuesday” broadcast on Dec. 18, 2012. “We also listened to (the) industry and took into account reports indicating that, while their members were moving forward on ICD-10, they could benefit from the additional time. In fact, industry feedback showed that up to 25 percent of providers may not have been ready by 2013.”

The fact that CMS is even considering a limited test is a reversal from its position voiced last June, when the agency announced that it would not be conducting end-to-end testing. In September 2012, as reported by ICD10monitor, 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.

“CMS will only be testing the technical side of the claim – meaning, ‘Can the claim make it in the front door of the payer?’ – not testing whether the claim will be paid, and at what rate,” Robert A. Tennant, senior policy advisor for the Medical Group Management Association, told ICD10monitor in an email.

Former hospital executive-turned-healthcare consultant Lyman G. Sornberger said the one week of testing is not what he calls “ample” since, as Sornberger explained, many budgets had various assumptions and timelines.

“To limit the test to this very short window with this notice is unreasonable,” Sornberger, now president and CEO of LGS Health Care Consultants, said. The former executive director of revenue cycle management for the Cleveland Clinic Health System told ICD10monitor that there should be multiple test periods.

“Four of my seven clients will be ready (in the) second and third quarter of 2014, and that was designed around no CMS feedback on a test period prior to that – as far as I know,” Sornberger said.

Sornberger’s take on the CMS testing week is that, in his words, “this feels very much like a CMS pilot to benefit their validation without an end-to-end testing that would benefit the provider.”

Juliet Santos, former senior director of HIMSS, agreed with Sornberger about the limited test time.

“One week of testing will not be sufficient and will most likely need to be adjusted to more realistically accommodate the complexity of ICD-10,” Santos, now an executive with the Lott QA Group, said.

Echoing the concern of the short notice of the intent to engage in technical testing was Deborah Grider, senior manager for Blue & Company.

“The timing is not beneficial to hospitals and providers who are planning to conduct dual coding in April,” Grider explained. “This gives us such a short window to accomplish this important implementation step.” 

Grider is also concerned about the timeline, which only offers five days of testing.

“What if there are issues and the testing fails – then what?” Grider asked. “With these issues that are still looming concerns, we might have to push back dual coding to May or possibly even June, which gives the industry less time to prepare for proficiency issues and to reduce the effect of productivity decline.”

Sounding an optimistic note was healthcare consultant Ellen VanBuskirk, who hopes that the feedback CMS is soliciting regarding the national test week will be beneficial.

“While the approach outlined is focused on front-end testing, which will identify major issues and provide feedback to CMS to better manage (the) risk of October 2014, the critical issue stated is the intent to solicit other ideas on how to test ICD-10,” VanBuskirk said. “Let the work begin!”


Up until the two recent congressional hearings into the botched launch of the Obama administration’s HealthCare.gov, when U.S. Health and Human Services Secretary Kathleen Sebelius faced a blistering confrontation from House Republicans, there was no outward signal that CMS was reconsidering its stance on testing (let alone the end-to-end testing that the agency had previously abandoned).

But could that fateful exchange between Sebelius and U.S. Rep. Joe Pitts, R-Pa. – when the congressman asked the secretary if she believed two weeks of site testing before Oct. 1 was "enough time" – have been the difference? Sebelius responded "clearly not," further noting that “we did not adequately do end-to-end testing.”

Now, with less than a year before ICD-10 goes into use, end-to-end testing would seem like it might emerge as a priority among providers. But that’s not necessarily the case.

In a poll conducted during a recent Talk-Ten-Tuesday Internet radio broadcast, 49 percent of listeners had not conducted end-to-end testing with trading partners

Do problems with the HealthCare.gov website offer any lessons for providers and payers when it comes to testing, especially being as Sebelius acknowledged that her department didn’t allow enough time for end-to-end testing?

“There must be robust end-to-end testing of all processes and systems involved in a major new initiative well before the live date – and that must include ‘unusual’ situations to determine what will happen under those situations,” advised Stanley Nachimson, a former CMS official who worked for the agency during the transition from 4010 to 5010 and now serves as principal of Nachimson Advisors.

“There must then be time to fix any issues involved before the live date,” Nachimson added.

There is hope among industry experts and hospital executives that CMS is reconsidering its stance on end-to-end testing, given its experience not only with HealthCare.gov, but also the aforementioned 4010-to-5010 upgrade problems experienced a year ago. Tauana McDonald, a vice president at the CHE Trinity Health system office located in Livonia, Mich. is among them.

“Thinking back to the nightmares experienced with the 5010 migration, (which were) mostly caused by no end-to-end testing, I think it is welcome news that CMS is reconsidering its initial stance on end-to-end testing,” McDonald told ICD10monitor. “End-to-end testing is a key step to ensuring (that) our transition to ICD-10 is as smooth as possible for all parties.” 

There is hope the industry will rally around what MGMA’s Robert Tennant is expecting when it comes to reconsidering end-to-end testing.

“I anticipate that MGMA and others will be communicating our concern regarding the nature of this proposal, and recommending that the agency expand the scope of the testing,” Tennant said.

Meanwhile, the clock keeps ticking.  

Disclaimer: Every reasonable effort was made to ensure the accuracy of this information at the time it was published. However, due to the nature of industry changes over time we cannot guarantee its validity after the year it was published.
Chuck Buck

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

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