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Updated on: March 16, 2016

ICD-10: Testing, Vendor, Provider Readiness Uncertain

Original story posted on: June 28, 2013

“The whole issue of end-to-end testing is a relatively large, time-consuming, and expensive investment for all parties,” stated Dennis Winkler, technical program director of program management at Michigan Blue Cross/Blue Shield of Michigan. “Historically, it usually ends up being used by larger providers, institutions and payers.”

John Wollman, executive vice president of Highpoint Solutions, adds that end-to-end testing also is not “immediately implementable.” In fact, at this point, many providers, clearinghouses, and payers don’t have the systems in place to support end-to-end testing.


“As we’re hearing in surveys and from industry watchdogs, the plumbing quite frankly isn’t in place for the vast majority of providers and payers,” he says.

Winkler and Wollman joined ICD-10 Monitor’s June 26 Talk Ten Tuesday broadcast to discuss an alternative system of ICD-10 testing. In addition, Sue Bowman from the American Health Information Management Association (AHIMA) shared highlights of her testimony about ICD-10 implementation at the recent hearing by the U.S. Department of Health and Humans Services’ National Committee on Vital and Health Statistics (NCVHS), and Robert Tennant, senior policy advisor for the Medical Group Management Association (MGMA), presented key findings of a member survey.

Testing Content Only

Winkler wanted a way to engage more providers and deal with only ICD-10 information. Wollman worked with him and his team to develop their vision of content-based testing something for the “masses” that required little investment. However, he’s quick to point out that this alternative testing is not a replacement for end-to-end testing.

“Content-based testing and end-to-end testing go together and are not mutually exclusive,” said Winkler. “There’s always a need for larger institutions to go through the entire process. Our concern is that the majority of providers aren’t in a position to test like that. They don’t have the staff, dollars or time.”

To address those realities, the Blue Cross/Blue Shield of Michigan team re-engineered key claims to bring them back to medical scenarios; member information, such as copayments and deductibles, was incorporated. The scenarios are sent to providers, who, in turn, submit only the I-10 information, and the payer processes the claim. Providers receive the results via email.

Winkler and his team wanted to find out how the I-10 information differed from the ICD-9 baseline. The data gathered also indicates how others in that provider’s peer group responded to the same scenarios.

Survey Reveals Testing Delays

Robert Tennant reported on the findings of a recent survey conducted of a cross-section of MGMA members—1,200 of them, in fact, from medical groups where 50,000 physicians practice. Most reported that, first and foremost, they need to upgrade or replace their electronic health record systems (EHRs) and practice management software to accommodate the I-10 codes.

When asked when they expect to test internally, the answers were “disquieting,” said Tennant: 45 percent said they hadn’t even heard from their vendors and 35 percent hoped to test between January and October 2014, but, again, vendors have not supplied specific dates. Other key trading partners—major health plans and clearinghouses—also are lagging behind: 60 percent of the respondents haven’t heard anything about when their clearinghouses would accept test claims, and 71 percent don’t know when their major health plans would begin testing.

“We tend to forget that clearinghouses have a major role to play, and the vast majority of our respondents said they submit 60 to 100 percent of their claims to clearinghouses,” said Tennant. “The problem with that is that a clearinghouse cannot solve all of the practice’s ICD-10 issues, although they can help.” One issue, for example, is the fact that 20 percent of the practices are still submitting version 4010 claims, which means that they won’t be able to submit I-10 codes until they switch over to the 5010.

All in all, reported Tennant, the “readiness levels of practice trading partners leave something to be desired,” and MGMA will continue tracking progress up to the compliance date.

Adding insult to injury was CMS’s announcement that it would not do end-to-end testing. As a result, said Tennant, “Many commercial plans may follow suit.” However, on this point, Sue Bowman reported that CMS did mention, at the NCVHS hearing on ICD-10, that, in light of industry concerns, it would reconsider its decision about end-to-end testing.

Other key concerns of MGMA members were “interesting but not surprising,” Tennant reported. They include clinical documentation changes and the loss of clinician and coder productivity after ICD-10 is implemented.

Bowman Focuses on Data

Documentation was also on the mind of Bowman when she testified at the ICD-10 hearing. “Ensuring the accuracy of coded data has never been more important,” she emphasized. “That depends upon the quality of the underlying medical record documentation and application of standard rules and coding standards.”

Bowman clarified that it’s not so much about talking about new uses of the data but the ability to have “more detailed data, knowing what can be done with it, and recognizing that we won’t get that data unless the underlying documentation is there as well.”

She also explained that code sets are communication tools with uses far beyond the well-known ones of reimbursement, such as quality, fraud and abuse, clinical care, public health, and research. Many of the newer uses, like the implementation of the EHR and meaningful use, a change in reimbursement models, and healthcare reform, have, said Bowman, “emphasized the widening gap behind the data that we have and what we need.”


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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.
Janis Oppelt

Janis keeps the wheel of words rolling for Panacea®'s publishing division. Her roles include researching, writing, and editing newsletters, special reports, and articles for RACMonitor.com and ICD10Monitor.com; coordinating the compliance question of the week; and contributing to the annual book-update process. She has 20 years of experience in topics related to Medicare regulations and compliance.

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