HFMA Comment Letter: CMS Should Test the Readiness for ICD-10 Implementation

January 9, 2014

Ms. Marilyn Tavenner
Administrator
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW, Room 310G
Washington, DC 20201

Re: Testing the readiness for ICD-10 implementation

Dear Ms. Tavenner:

On behalf of our 40,000 healthcare financial professionals representing hospitals, physician practices, and post-acute-care providers, the Healthcare Financial Management Association (HFMA) urges the Centers for Medicare & Medicaid Services (CMS) to undertake a comprehensive approach to testing the readiness of the Medicare contractors and state Medicaid agencies for the October 1, 2014, ICD-10 implementation. We recognize CMS’s efforts to provide educational opportunities and implementation checklists to providers. We are concerned, however, that at this point it is not clear what the scope or timeline for testing with the CMS contractors will be. Failure to appropriately test all aspects of the ICD-10 implementation may result in a significant cash flow disruption for providers shortly after the October 1, 2014, implementation date. Should a significant cash flow disruption occur, as is possible without necessary end-to-end test accompanied by sufficient time to remediate any issues, it would have a negative impact on access to care for all patients, including Medicare beneficiaries.

End-to-end testing is designed not only to ensure that the Medicare contractors are prepared to accurately accept claims containing ICD-10 codes, but also to validate the integrity of the claims adjudication processing. This step allows providers to confirm that the payment assigned by the contractors and agencies matches the expected payment as calculated by the provider.

Scope and timing of the testing work is also critical to the success of the October 1, 2014, implementation. Testing should be available to all providers who opt to participate, regardless of size, and testing should begin no later than January 2014. It is critical that providers and CMS allow sufficient time to not only test the systems, but also to correct issues identified during the testing process. Anything less than an end-to-end test will not be adequate to validate the readiness of providers, CMS, and the state Medicaid agencies for the October 1 transition.

We also believe that testing for this implementation is not optional: it is required under Section 1104 of the Patient Protection and Affordable Care Act (ACA). Specifically, the ACA states that a health plan, which includes Medicare and Medicaid, must provide documentation that it is in compliance with all HIPAA transaction standards and operating rules, including ICD-10. Completed end-to-end testing with partners (hospitals, physicians, other providers) is how health plans must demonstrate compliance.

HFMA is ready to assist CMS in defining the details of the testing process and sharing information about it with our members. All contractors should be testing at the same time with volume controls defined to allow all providers to participate in the testing processes. Testing results need to be made available as soon as possible to the entire provider community, allowing providers and their vendors to continue the implementation process and remediate identified issues.

We are also concerned that the ICD-10 implementation has the potential to result in significant disruption of the claims processing systems, resulting in cash flow deficiencies for providers of all sizes. This implementation is mandatory for all providers on the same date. The sheer magnitude of this change opens the door to system issues and failures. We encourage CMS to be prepared to offer advance payments to all Medicare or Medicaid enrolled providers requesting such assistance.

HFMA looks forward to any opportunity to provide assistance or comments to support CMS’s efforts to implement ICD-10. As an organization, we take pride in our long history of providing balanced, objective financial technical expertise to Congress, CMS, and advisory groups. We are at your service to help CMS gain a balanced perspective on this complex issue. If you have additional questions, you may reach me or Richard Gundling, Vice President of HFMA’s Washington, DC, office, at (202) 296-2920. The Association and I look forward to working with you.

Sincerely,

Joseph J. Fifer, FHFMA, CPA
President and Chief Executive Officer
Healthcare Financial Management Association

CC: Jonathan Blum, Deputy Administrator and Director, CMS

About HFMA

HFMA is the nation’s leading membership organization for more than 40,000 healthcare financial management professionals. Our members are widely diverse, employed by hospitals, integrated delivery systems, managed care organizations, ambulatory and long-term care facilities, physician practices, accounting and consulting firms, and insurance companies. Members’ positions include chief executive officer, chief financial officer, controller, patient accounts manager, accountant, and consultant.

HFMA is a nonpartisan professional practice organization. As part of its education, information, and professional development services, HFMA develops and promotes ethical, high-quality healthcare finance practices. HFMA works with a broad cross-section of stakeholders to improve the healthcare industry by identifying and bridging gaps in knowledge, best practices, and standards.