For many months now, the AAFP has urged family physicians to prepare for this year's Oct. 1 deadline for implementation of the ICD-10-CM code sets for outpatient diagnostic coding.
A big part of that preparation entails adequate end-to-end testing between hospitals, large health systems, independent physician practices and the health insurance companies who pay for a good deal of those health care services. In particular, it is important that the nation's largest private payers including UnitedHealthcare (UHC), Aetna, BlueCross BlueShield (BCBS) and Humana, are ready for the transition so payments to physicians are not delayed.
Thus, in early February, Laura Schmidt, an AAFP private sector advocacy strategist, sent key contacts at each of the companies a list of questions. "We are interested in confirming that (your company) will be ready to fully process claims using ICD-10 codes as of Oct. 1, 2014," wrote Schmidt, who then posed her questions on readiness.
- The AAFP recently asked some of America's largest private health insurance companies if they would be ready on Oct. 1 for implementation of the ICD-10-CM code sets for outpatient diagnostic coding.
- Representatives from UnitedHealthcare, Aetna, BlueCross BlueShield and Humana shared, among other things, their testing processes and contingency plans.
- All of the health plans said they would be ready by the implementation deadline, but some indicated concern that small private practices were not further along in their preparations.
For example, the AAFP asked each insurer to
- confirm that testing of their internal products and processes was complete;
- acknowledge that "upstream" testing of incoming data/processes from the clearinghouses and other health IT companies with which the insurer partnered was complete;
- identify how many provider groups had, or planned to, submit claims to test the "downstream" process;
- share any problems or issues that testing revealed;
- ensure the availability of contingency plans to tackle problem areas;
- provide opportunities for multiple testing episodes for physician practices to test the claims process; and
- divulge plans for how any post-implementation issues would be resolved.
Schmidt said payers indicated that they are working to ensure success with their larger clients first -- such as hospital systems and large practice groups -- before moving on to readiness with smaller physician practices.
All of the payers had set up ICD-10 preparedness pages on their individual websites specifically dedicated to assisting physicians.
Most importantly, all of the health insurance companies who responded said they would be ready for the Oct. 1 deadline.
"Payers want this transition to run smoothly, too," said Schmidt. "They've invested a lot of time and money into the ICD-10 implementation, just as family physicians have. The bottom line is that no business, big or small, involved in this effort can afford a slowdown in its billing and payment processes."
Regarding specific payer readiness, Aetna Senior Medical Director Christopher Jagmin, M.D., reported that his company began large-scale internal testing and targeted external testing in 2013 and would continue throughout 2014.
"We plan to use what we learned from our testing as we work with all of our providers and vendors in coming months," said Jagmin, who is a family physician and an AAFP member. "We are evaluating the best communication mechanisms for sharing our testing results industrywide," he added.
Humana said it was developing a payer/provider collaboration ICD-10 testing program for physicians scheduled for rollout in the spring. Humana listed its top three ICD-10 concerns as
- accurate use of ICD-10 coding for claims submitted after Oct. 1;
- vendor readiness to support ICD-10 early enough for physicians to prepare for the transition date; and
- physician readiness to support ICD-10 on Oct. 1.
In addition, Humana said it was developing a series of webinars to help answer physician questions and indicated that its ICD-10 testing programs with facilities and physician offices would "help mitigate any at-risk claims issues."
A BCBS Association spokesperson said he expected each of the 37 independent locally operated BCBS plans to participate in the downstream testing process. He said most plans would conduct multiple rounds of testing, "but it is an expensive process and has limits."
In addition, BCBS expressed concern that small physician practices were not further along in the process and suggested that a lack of preparedness by health IT vendor partners was part of the problem. "This, in turn, will probably create bottlenecks in testing downstream," said the spokesperson.
Jerry Frank, M.D., UHC's national medical director of physician engagement, said his company had performed extensive internal testing "to verify predictable processing outcomes" since March 2013 and would conclude testing in June. He added that external downstream testing would begin in April and continue through September.
Frank, also an AAFP member, acknowledged that UHC did not have the resources necessary to test claims for all physicians who requested such testing. He pointed to a contingency plan already developed by which UHC will publish key findings from ICD-10 claims testing with selected physicians on its provider information portals.
"Providers can review summarized test findings so they can learn from the experience of those who were able to submit test ICD-10 claims," said Frank. In addition, as part of the planning process, UHC already has created a team dedicated to identifying and resolving ICD-10 issues that crop up after the new code sets become mandatory next fall.
Schmidt said overall, findings from the payer survey were positive. "Insurers indicated that they'll be ready for the Oct. 1 ICD-10 deadline, and our members need to assume a sense of urgency to be ready as well," she said.
Related AAFP News Coverage
AAFP Raises Serious Questions About ICD-10 Testing, Readiness
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FAQ on ICD-10
ICD-10 Implementation Timeline(www.cms.gov)