Challenges, variability abound as Mass. launches ICD-10 collaborative testing program

The Massachusetts Health Data Consortium (MHDC) has launched its collaborative testing program for ICD-10 to learn “where there are big differences, where there are disruptions and where coding could be improved,” said Denny Brennan, executive director of the organization, during its March 10 conference on ICD-10 implementation.

The testing effort has 18 committed provider participants and 17 pending, which represents 80 percent of the acute care marketplace in the state. Nine health plans also are involved. The goal in testing is development of scalable, repeatable and measurable processes.

“Managing complexity where we have incredible fragmentation requires agility,” said Micky Tripathi, PhD, president and CEO of the Massachusetts eHealth Collaborative, about the testing effort. The various stakeholders started with some ideas but knew they wanted to be able to react on the fly.

First was developing a testing community structure. They based it on health plans because plans have defined communities. “There are commonalities within a plan you have to recognize,” he said.

They also had to learn and remember that this is a collaborative, Tripathi said. Post-adjudication financial impact analysis results were provided back to each provider confidentially but ICD-10 coding analysis results can be shared among providers and across communities as stakeholders desire.

Testing includes three levels: 5010 transaction, which is syntax and message conformance; code variation; and financial impact analysis to see how close organizations are to financial neutrality. “We need a big, deep, rich library of dual-coded scenarios,” Tripathi said, which MHDC has through its vendor partner, Edifecs.

“Program success requires high tolerance for ambiguity and agility in design and execution,” he said. It deviates from the ideal model, he added, because “every day we’re uncovering new things.”

One significant challenge with the testing effort is that most providers want to use their own scenarios. “That’s not the way the system works out of the box,” said Tripathi. Most want to use historical production plans to take things that have already been adjudicated and run them again to see how they compare. Meanwhile, only some providers can access their old 835 forms. “We need flexibility according to the capabilities of the provider.” Some large providers have multiple testing sites.  

Payers don’t want to get involved in coding validation, said Tripathi. Each has a different test environment set up, different readiness dates and testing capacity. Some providers want to do financial analysis in their own system. “This is a flavor of the kinds of morphing we’ve had to do for this to be something everyone feels like they’re benefiting from. There’s a lot they can do better together than on their own.”

The program is using a dashboard to “meaningfully mark progress in a way we can get our arms around. There’s noise every day but we’re on track overall.” Participants can see what others are doing. Everyone is marching forward to the same rough outline, he said, even though each organization’s details differs a lot.

Smaller providers have testing needs as well, said Tripathi, but that doesn’t “involve the deeper customization of big providers. We’re hoping that will take shape in the next couple of weeks.”

Early adopters help everyone, said Brennan. “For early adopters, patience is probably a virtue but we’re trying to make sure early adopters aren’t waiting too long.” Every provider is in a different place regarding readiness but “we need more in the same place so we can test in a reasonable sized group.”

The collaborative expects to begin actual ICD-10 testing in April.