10 ICD-10 Questions Physician Senators Want CMS to Answer this Week

Concerned that the Centers for Medicare and Medicaid Services (CMS) plans for front-end testing of the ICD-10 system during the week of March 3 is too brief and too limited in scope, U.S. Senators and physicians Tom Coburn, M.D. (R-Okla.), John Barrasso, M.D. (R-Wyo.), John Boozman, O.D. (R-Ark.), and Rand Paul, M.D. (R-Ky.) have requested that the Centers for Medicare and Medicaid Services (CMS) answer their questions about the testing by February 26.

CMS has already delayed the implementation of the ICD-10 code sets multiple times, and as advocates for the change point out, the rest of the western world has already switched over. However, few nations have as complicated a health care reimbursement system as the United States, and the Republican Senators are not confident that the switch will go smoothly. They point to the problems with the Healthcare.gov rollout and CMS’s own advice that health care providers put aside money in an “emergency fund” ahead of October 1 change from ICD-9 to ICD-10 codes in case the switch causes delays in the reimbursement of claims.

CMS announced last week that it will conduct a limited set of end-to-end testing of claims this summer to give providers confidence that the system will work. (See page 4 or CMS's "MLN Matters.") But the Senators want even more granular assurances. In the letter to CMS Administrator Marilyn Tavenner they ask the following 10 questions:

1. What metrics will CMS use to evaluate the success of the ICD-10 testing period in March?  What are the targets CMS has set for each of these metrics to determine whether the testing period was successful?
2. Will the testing period allow Medicare providers to test accurate and prompt claim adjudication? If not, does CMS plan on executing more testing periods before full implementation (currently scheduled for October 1, 2014) to ensure claims can be accurately submitted and paid under ICD-10?
3. Before full implementation, does CMS plan to test the appeal process for claims submitted due to incorrect ICD-10 codes as providers and staff transition to the new system?
4. When does CMS plan to release results from the testing period to the public, so that providers and other entities may make necessary changes to their systems? 
5. How will CMS measure the ICD-10 readiness of Medicare Administrative Contractors (MAC) and state Medicaid agencies before full implementation? Will CMS require MACs and Medicaid to demonstrate successful end-to-end testing before all providers have to switch to ICD-10?  What is the current ICD-10 readiness of these entities?
6. Provide a list of any internal or third-party testing CMS has scheduled before full implementation of the ICD-10 coding system.
7. Will CMS perform full testing of Recovery Audit Contractors (RAC), the Fraud Prevention System (FPS), and other anti-fraud efforts to ensure full capability to perform anti-fraud investigations?  If so, what metrics and targets will CMS use to ensure ICD-10 readiness of RACs and the FPS?
8. When will CMS release a crosswalk of Local Coverage Determinations and all other Medicare claim transaction edits associated with ICD-10 codes?
9. How often has CMS studied the ICD-10 readiness of the providers and other third parties?  What industry analyzes or surveys is CMS relying on for information on the ICD-10 readiness of providers and other third parties?
10. Has studied CMS the impact the ICD-10 transition may have on upcoding?  Describe the results of any findings.

The Senators are in favor of a delay and previously introduced the Cutting Costly Codes Act, S. 972, which would prohibit HHS from moving forward with the ICD-10 transition.