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Updated on: November 21, 2016

ICD-10 Transition Testing Proposed

Original story posted on: May 15, 2015

On the heels of H.R. 2126, a bill introduced by U.S. Rep. Ted Poe (R-Texas) “to prohibit the Secretary of Health and Human Services (HHS) from replacing ICD-9 with ICD-10 in implementing the HIPAA code set standards,” comes H.R. 2247.


Unlike Poe’s bill, which was introduced two weeks ago, the latest piece of proposed legislation would require an 18-month transition period for the purposes of testing the submittal of ICD-10 claims. Titled the “Increasing Clarity for Doctors by Transitioning Effectively Now Act (ICD-TEN Act),” the bill was introduced last Tuesday by Rep. Diane Black (R-Tenn.).

Black’s bill would “require the Secretary of Health and Human Services to provide for transparent testing to assess the transition under the Medicare fee-for-service claims processing system from the ICD-9 to the ICD-10 standard, and for other purposes.” Moreover, her bill would require the Centers for Medicare & Medicaid Services (CMS) to accept dual coding: claims coded in either ICD-9 or ICD-10. During the “transition testing” period, Black’s bill would prohibit CMS from denying reimbursement claims using “an unspecified or inaccurate sub-code." Finally, the bill would require HHS to conduct what the bill describes as “comprehensive end-to-end testing,” which would require that the agency make such testing available to all HIPAA-covered entities.

“The release of H.R. 2247 is further indication that Congress is taking its role of providing oversight of the implementation (of) ICD-10 seriously,” said Robert M. Tennant, director of health information technology policy at the Medical Group Management Association (MGMA). “There is growing concern in the physician practice community that their critical trading partners will not be ready in time to meet the Oct. 1, 2015 compliance date.”

Tennant says that while H.R. 2247 does not alleviate all concerns, he believes the bill addresses a number of critical issues. Specifically, he noted the importance of the notions that testing would be required by CMS and that CMS would have to offer end-to-end testing to all providers. Tennant also pointed out that the bill would include a provision to ascertain the readiness level of Medicare by requiring it to certify to Congress that its systems are ready.  Finally, Tennant recognized that due to the required use of granular ICD-10 diagnosis codes, no Medicare claim could be denied “due solely to the use of an unspecified or inaccurate sub-code.”

“If the transition is to go smoothly, CMS must take aggressive steps to ensure that physician practices and their trading partners are ready for Oct. 1,” Tennant said in an email to ICD10monitor. “If any ‘link’ in the implementation ‘chain’ is not ready, practice cash flow is at risk, as is their ability to serve their patients.”

On the other hand, the American Health Information Management Association (AHIMA) has come out strongly opposing the bill, saying that mandatory end-to-end testing that would certify that Medicare systems are functioning is unnecessary.

“CMS has already been conducting end-to-end testing for some time,” the association noted in a written statement. “After the first Medicare fee-for-service end-to-end testing in January, CMS reported that only 3 percent of rejected claims were due to invalid submission of an ICD-10 code.”

AHIMA also goes on record in its statement calling for “advanced payments” for physicians experiencing difficulties with their ICD-10 implementation.

“Testing has demonstrated that CMS systems are ready to accept and process ICD-10 claims,” the statement read. “To further mitigate this risk, AHIMA recommends that CMS grant ‘advance payments’ to any physicians that do experience cash flow disruptions as a result of the ICD-10 transition.”

For both Black and Poe to prevail, they’ll need to convince members of the powerful House of Representatives Committee on Energy and Commerce, to which both bills have been referred.



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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