ED Coding and Reimbursement Alert

You’ll want to know the four pronged approach CMS has designed to test for ICD-10 readiness

It’s déjà vu all over again, but now is the time to begin preparing for October 2015 ICD-10 implementation. 

CMS stands firm on 2015 date: CMS recently announced Oct. 1, 2015, as the new effective date for the ICD-10 code set and its planned ICD-10 testing schedule. You will likely recall it was forced to delay implementation from the originally planned October 2014 date with passage of the Protecting Access to Medicare Act of 2014, which includes language prohibiting CMS from implementing the new code set prior to that date. Although the language would have allowed additional delay, CMS has made it clear further postponements should not be expected. 

Heads Up: 4-Pronged Testing Ahead

A MedLearn Matters special addition article, (SE1409), outlines the planned testing approach CMS will take, including a comprehensive four-pronged approach to preparedness and testing for ICD-10 to ensure that it and the fee-for-service (FFS) provider community will be ready. The four-pronged approach includes the following: 

1. CMS internal testing of its claims processing systems 

CMS has a rigorous testing program for its Medicare FFS claims processing systems that supports the implementation of four quarterly releases per year. Each release is supported by a three-tiered and time-sensitive testing methodology: 

• Alpha testing is performed by each FFS claims processing system maintainer for 4 weeks; 
• Beta testing is performed by a separate Integration Contractor for 8 weeks; and 
• Acceptance testing is performed by each MAC for 4 weeks to ensure that local coverage requirements are met and the systems are functioning as expected. 

CMS has been testing system changes to support ICD-10 since 2011 and has announced that as of October 1, 2013, all Medicare FFS claims processing systems were ready for ICD-10 implementation. However, CMS continues to test its ICD-10 software changes with each quarterly release. 

2. Provider-initiated beta testing tools

In preparation for ICD-10, CMS recommends that you leverage the variety of beta versions of its software that include ICD-10 codes as well as National Coverage Determination (NCD) and Local Coverage Determination (LCD) code crosswalks to test the readiness of your own systems. To this end, testing tools are available for download on the CMS website including NCDs and LCDs converted from International Classification of Diseases, 9th Edition (ICD-9) to ICD-10and a pilot version of the October 2013 Integrated Outpatient Code Editor (IOCE) that utilizes ICD-10-CM. The final version of the IOCE that utilizes ICD-10-CM is scheduled for release in the near future. 

3. Acknowledgement testing

Providers, billing companies, and clearinghouses are encouraged to submit acknowledgement test claims anytime up to the Oct. 1, 2015 implementation date.

 In addition, CMS will be highlighting this testing by offering three separate weeks of ICD-10 acknowledgement testing in November 2014, March 2015, and June 2015. These special acknowledgement testing weeks give submitters access to real-time help desk support and allows CMS to analyze testing data. 

What this means: This testing allows all providers, billing companies, and clearinghouses the opportunity to determine whether CMS will be able to accept their claims with ICD-10 codes. While test claims will not be adjudicated, the MACs will return an acknowledgment to the submitter (a 277A) that confirms whether the submitted test claims were accepted or rejected. 

4. End-to-end testing 

If you want to take it a step further, CMS plans to offer three separate end-to-end testing opportunities. Each opportunity will be open to a limited number of 2,550 providers that volunteer for this testing over the course of the three testing periods. End-to-end testing includes the submission of test claims to Medicare with ICD-10 codes and the provider’s receipt of a Remittance Advice (RA) that explains the adjudication of the claims. The goal of this testing is to demonstrate that: 

• Providers or submitters are able to successfully submit claims containing ICD-10 codes to the Medicare FFS claims systems; 
• CMS software changes made to support ICD-10 result in appropriately adjudicated claims (based on the pricing data used for testing purposes); and 
• Accurate RAs are produced. 

The sample group of participants will be selected to represent a broad cross-section of provider types, claims types, and submitter types. 

Want to try it? If you wish to take advantages of that opportunity watch for additional details about the end-to-end testing process will be disseminated in a future MLN Matters article.

Don’t miss: These programs are for Medicare only and do not guarantee other payers will be ready and able to accept your ICD-10 claims by the October implementation date.

The full text of the MedLearn Matters article can be found at the following link: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1409.pdf.