Medicare Compliance & Reimbursement

ICD-10:

Associations Fear ICD-10 Transfer Might Trigger Massive Denials

End-to-end testing reveals potential problems.

If you have questions about the ICD-10 transition, you’re not alone. Specialty societies, including the American Medical Association (AMA), are waiting for answers, too.

The AMA was among 100 medical groups that wrote to the Centers for Medicare & Medicaid Services (CMS) on March 4 seeking responses to ICD-10 issues that they believe have not been appropriately addressed. Although the groups didn’t go so far as to request a delay to the Oct. 1 implementation date, they did express strong concerns about the transition in the 7-page letter to Acting CMS Administrator Andrew Slavitt.

Chief among the issues were the results of CMS’s end-to-end testing periods, which revealed claim acceptance rates in the 76 to 89 percent range. This range clashes significantly with the current standard Medicare acceptance rate of 95 to 98 percent, the letter stated. Because only a small number of practices participated in the testing, the groups worry that when all Medicare practices start submitting claims, that percentage rate will extrapolate out to the community at large, triggering massive denials.

“The likelihood that Medicare will reject nearly one in five of the millions of claims that go through our complex health care system each day represents an intolerable and unnecessary disruption to physician practices,” said AMA President Robert M. Wah, MD in a March 4 statement. “Robust contingency plans must be ready on day one of the ICD-10 switchover to save precious health care dollars and reduce unnecessary administrative tasks that take valuable time and resources away from patient care.”

As we reported in Medicare Compliance & Reimbursement Alert  vol. 41 no. 6, the most recent CMS end-to-end testing period (Jan. 26 to Feb. 3) resulted in an 81-percent success rate, the agency said. The remaining claims were rejected for three main reasons, as follows, according to the most recent statistics released by CMS:

  • Invalid submission of ICD-9 codes (seen in 3 percent of rejected claims)
  • Invalid submission of ICD-10 codes (as demonstrated by another three percent of claims that didn’t pass through the system)
  • Errors unrelated to ICD-10, such as using an incorrect NPI, an invalid date, the wrong place of service or an incorrect HCPCS code (seen in 13 percent of rejected claims).

Keep an eye on these pages for more on this topic as the ICD-10 implementation date nears.