Colorado Medical Society

ICD-10 update

Sunday, March 01, 2015 11:30 AM

The American Medical Association and state medical associations around the country drafted a letter in late February to Andrew Slavitt, acting administrator for the Centers for Medicare and Medicaid Services (federal CMS), asking the agency to consider and act upon several potential pitfalls with the implementation of the International Classification of Diseases, 10th Revision (ICD-10). The letter stated that the organizations are “gravely concerned” that many aspects of ICD-10 have not been fully assessed and that contingency plans may be inadequate if serious disruptions occur on or after Oct. 1, 2015 – the implementation deadline for ICD-10.

First, the AMA is concerned with limited acknowledgement testing. While they express appreciation for the training, educational tools, and other efforts by the federal CMS to prepare physicians and other health care entities for the ICD-10 transition, “there still remains a lack of industry-wide, thorough end-to-end testing of ICD-10 in administrative transactions.” Testing in March and November 2014 only tested if the claim was initially accepted through the claims processing system, not how the claim will process completely.

And while the federal CMS conducted a more robust end-to-end testing in January and will conduct two more testing weeks in April and July 2015, the three test dates only include a sample size of 2,550 volunteer testers – a small fraction of all Medicare providers that could be skewed toward those most confident of their preparation. Plus, the federal CMS released only a broad overview of data for January; the AMA urges the federal CMS to release more detailed data.

Second, the AMA questions the ability to correctly collect and calculate quality data during and after the transition to ICD-10 due to potentially conflicting timelines. As the AMA points out, ICD-10 is scheduled to begin on Oct. 1, 2015, but the Physician Quality Reporting System (PQRS) and Meaningful Use (MU) quality reporting periods are based on the calendar year, meaning that physicians will have to report ICD-9 for the first part of the year and ICD-10 for the second. They ask the federal CMS to provide details on how it plans to ensure that the measure calculations for these programs are not adversely impacted by the transition to ICD-10.

Third, the AMA asks the federal CMS to mitigate risk to physicians by being prepared with extensive contingency plans in the event significant claims processing disruptions occur that cause physicians to go unpaid for any period of time. They suggest the federal CMS commit to granting “advance payments” as they had previously indicated was possible. In addition, the AMA is concerned that physicians will not have received software upgrades from their EHR vendors and have asked CMS to make information about vendor readiness available. Finally, the AMA asks that the federal CMS confirm and instruct contractors that they are prohibited from engaging in audits that are only predicated on code specificity and not potential fraud or abuse.

The AMA recognizes that implementation of ICD-10 is a massive undertaking. Asking physicians to assume this significant change at a time when they are being required to adopt new technology, re-engineer workflow and reform the way they deliver care will challenge their ability to care for patients and make investments to improve quality. The AMA asks for further dialogue to address concerns.

Denver-based CMS office names John Hannigan as new associate regional administrator

John Hannigan has been named the associate regional administrator for the Consortium for Medicare Financial Management and Fee for Service Operations (CFMFFSO), Centers for Medicare and Medicaid Services, in Denver. He will have a national role among the 10 regional offices of the federal CMS on ICD-10, HITECH, and professional relations, as well as responsibility for all Medicare fee-for-service and financial management operations for federal CMS regions 7 and 8.

Each regional office has an outreach component to provide resources and assistance to regional providers through staff who are familiar with national and local issues. Hannigan will act as the conduit between the central office in Baltimore and the regional office in Denver “to help them reach and support providers where they live and work.”

“All of the regions have someone local, with an understanding of local influences, that physicians can go to with questions or concerns,” Hannigan said. “The regional offices play a key role in representing the agency, delivering key messages, and gathering input from the field. If we don’t have the answer at hand, we’ll coordinate with the central office to represent regional stakeholders with an understanding of what’s happening in the region and with their business.”