Dear Acting Administrator Slavitt:
The undersigned organizations are writing to you concerning the agency’s implementation plans
for moving to ICD-10, a code set named under the Health Insurance Portability and
Accountability Act (HIPAA) that will be required for use by physicians and others starting
October 1, 2015. The transition to ICD-10 represents one of the largest technical, operational,
and business implementations in the health care industry in the past several decades. Given the
profound impact this will have on physicians, we have a number of concerns that do not appear
to be addressed by the Centers for Medicare & Medicaid Services’ (CMS) current transition
plan.
Testing
We appreciate the training, educational tools, and other efforts by CMS to prepare physicians
and other health care entities for the ICD-10 transition. Despite these efforts, there still remains
a lack of industry-wide, thorough end-to-end testing of ICD-10 in administrative transactions.
CMS conducted acknowledgement testing of claims for one week in March and November 2014
and additional weeks are planned in March and June 2015. Acknowledgement testing, however,
is limited in that it only tests that the claim will be initially accepted through the claims
processing system. It provides no information about if and how the claim will process
completely, ensuring payment to physicians.
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