AAFP Raises Serious Questions About ICD-10 Testing, Readiness

February 27, 2014 04:20 pm Sheri Porter

The AAFP once again appealed to HHS Secretary Kathleen Sebelius to vary her course regarding the fast-approaching deadline for the nation's transition to the ICD-10-CM code sets for outpatient diagnostic coding.

In a Feb. 25 letter to Sebelius, AAFP Board Chair Jeff Cain, M.D., of Denver, focused on the Oct. 1 deadline for implementation of ICD-10. The Academy is "deeply concerned" about possible system failures stemming from a lack of appropriate education and adequate end-to-end testing before the deadline, said Cain. Testing, in particular, would highlight system flaws prior to implementation of ICD-10 and the implicit requirement that physicians submit all claims using the ICD-10 code set.

To date, CMS has focused its training and testing resources on hospitals and large health systems "with an almost complete disregard for small- and medium-sized physician practices," said Cain.

Such practices represent the backbone of family medicine in America, and yet many of them lack the training resources necessary for a successful transition and, therefore, will not be prepared for implementation in concert with their various payers by the deadline, he added.

Story highlights
  • In a letter to HHS Secretary Kathleen Sebelius, the AAFP said training and end-to-end testing for the transition to the ICD-10-CM codes sets for outpatient diagnostic coding had been insufficient and asked for a delay in the deadline.
  • The Academy noted that CMS had focused its training and testing resources on hospitals and large health systems to the detriment of small- and medium-sized physician practices.
  • Regardless of HHS action or inaction, family physicians should continue their ICD-10 preparations.

"The resulting interruption to cash flow in October and beyond could potentially put these small- and medium-sized practices out of business," said Cain, and that, in turn, would negatively affect access to care for their patients. The coming crisis would hit rural and underserved patients particularly hard since small family medicine practices "are often the only source of primary care," in those communities, he reminded Sebelius.

Cain appealed to Seblius to take a number of steps to help alleviate the stress that ICD-10 preparations are placing on family physicians. Specifically, he urged HHS to

  • boost CMS funding for the creation of educational resources for physicians in smaller practices,
  • provide money to Medicare administrative contractors to be used for physician education about the correct use of ICD-10 codes and
  • delay the implementation of ICD-10 for at least another year.

Cain acknowledged that HHS had already pushed back the implementation date; however, family physicians across the country continue to report that their efforts to plan and test for implementation of ICD-10 with multiple health plans and payers have been "very challenging, overly expensive, chaotic and with only sporadic success."

According to CMS Administrator Marilyn Tavenner, M.A., speaking at the Healthcare Information and Management Systems Society conference in Florida, there will be no change in the deadline for ICD-10.

House Bill H.R. 1701 Waits in the Wings

It's possible that Congress may jump into the ICD-10 implementation tussle. Consider this: Last April, Rep. Ted Poe, R-Texas, introduced H.R. 1701, known as the Cutting Costly Codes Act of 2013(www.govtrack.us), which would prohibit HHS from implementing, administering or enforcing specified regulations that would replace ICD-9 with ICD-10.

The latest major House action on the bill occurred on April 26, 2013, when it was referred to the House Subcommittee on Health. The bill was introduced in the Senate on May 16, 2013; S. 972(www.govtrack.us) was referred to the Committee on Health, Education, Labor and Pensions.

Kevin Burke, director of the AAFP's Division of Government Relations, told AAFP News that even though the House and the Senate had not yet acted on the bill, "As the deadline for ICD-10 implementation approaches, it could be included in a larger bill that Congress takes up."

In the event that Sebelius continues to stand firm on the deadline for conversion to ICD-10, Cain asked HHS to require CMS to begin monthly testing between all physicians, health plans and payers. "We strongly recommend that CMS be required to offer end-to-end readiness testing each month for one week over the next five months (March to July)," said Cain.

He asked that results of those testing periods be made public and that the results include a "confidence interval on the effectiveness of the system well ahead of (the) Oct. 1 implementation deadline."

"If that confidence interval is less than 95 percent (in the months leading up to Oct. 1), we urge you to immediately delay implementation of ICD-10-CM for all physicians," said Cain.

Despite the fact that the AAFP and numerous other organizations continue to ask HHS and CMS to delay implementation of ICD-10, Kent Moore, the AAFP's senior strategist for physician payment, urged members to stay focused. "I cannot emphasize enough how important it is for family physicians to continue their ICD-10 preparations, because another delay may not be forthcoming," said Moore.

"Ultimately, being prepared to comply with ICD-10 will be critical to a physician's ability to be paid by Medicare and every other payer. Lack of preparedness for the transition would have a significant negative impact on a practice's revenue cycle," added Moore.


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