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Curbside Consult with Dr. Jayne 7/29/13

July 29, 2013 Dr. Jayne 1 Comment


Inga mentioned last week that MGMA had sent a letter to Health and Human Services Secretary Kathleen Sibelius. This was triggered by Medicare’s recent announcement that it does not intend to participate in end-to-end testing for ICD-10. In addition to MGMA, there are many more of us that agree that Medicare’s refusal to test with trading partners is problematic.

Medicare has a history of problems with claims backlogs whenever there are changes. My practice experienced this with previous transitions. Although our cash flow disruption was not as large as it could have been, it certainly wasn’t zero. Medicare has tested in the past for both 4010 and 5010 and the processes identified issues which could be resolved prior to the go-live date. CMS touted its testing week for HIPAA 5010 and it appeared to be very successful.

Medicare has said that practices should test with their commercial payers, but the problem there is the number of payers that take their direction from Medicare. If Medicare isn’t going to test, why should they spend resources testing with everyone in their networks?

The worst that can happen is claims are denied, which doesn’t hurt the insurance company and doesn’t hurt Medicare. It does hurt providers of all kinds, whether large or small, and the subsequent payment problems will ultimately have negative consequences for patients.

The MGMA letter calls out CMS for saying back in 2012 that there should be “industry wide best practices for the testing of ICD-10 and other standards.” CMS is requiring all state Medicaid payers to test with providers, but won’t participate itself. Providers are already nervous about ICD-10. This is going to add fuel to the fire.

It’s time for Medicare to eat its own dog food. What do you think? E-mail me.


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  1. Another issue we are concerned about is that there is an instantaneous cutover date with CMS. Before that date, they won’t accept ICD-10; after that date, they won’t accept ICD-9. That means every product in the vendor ecosystem has to be ready at the same time but without any opportunity to test realistic scenarios. And all the providers have to be ready on that day too. This seems pretty unrealistic and is bound to cause serious problems.

    It would be more sensible to have a period of month or so, where either ICD-9 or ICD-10 was accepted, so there would be a fallback in case of problems.

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