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Is ICD-10 End-to-End Testing as “Successful” as It Seems?

By Jennifer Bresnick

- CMS was able to conduct a “successful” initial week of ICD-10 end-to-end testing, says outgoing Administrator Marilyn Tavenner in an email update that shares details about the first comprehensive Medicare ICD-10 testing available for providers.  The testing, conducted during the last week of January, saw participation from 661 providers and clearinghouses submitting just under 15,000 test claims, 81 percent of which were accepted.

The Centers for Medicare and Medicaid Services

While the outcomes were generally good for those providers volunteering to take part in the testing, this self-selecting population of organizations may not necessarily reflect the readiness of the general healthcare community.

“This successful week of testing continues to put us on course for successful implementation of this important initiative that better reflects modern practice of medicine by Oct. 1, 2015,” wrote Tavenner in her email.

“Overall, participants in the January 26 to February 3 testing were able to successfully submit ICD-10 claims and have them processed through our billing systems. To the extent that some claims were rejected, most didn’t meet the mark because of errors unrelated to ICD-9 or ICD-10.”

Six percent of the 14,929 submitted claims were rejected for invalid submission of an ICD-9 or ICD-10 diagnosis or procedure code, while 13 percent were rejected due to non-ICD-10 issues, including incorrect national provider identifiers (NPIs), submitter IDs, places of service, or health insurance claim numbers.

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Some claims were also denied due to incorrect service dates.  Claims must use ICD-9 codes for services provided before October 1 and ICD-10 codes for those services performed on or after the October 1 implementation date, Tavenner reminds providers.

The ICD-10 end-to-end testing process is considered one of the most critical activities to partake in during preparation for the new codes, and CMS has been under an immense amount of pressure to open up testing opportunities to the provider community.  Providers can participate in ICD-10 acknowledgement testing at any time before the October 1, 2015 implementation date, or can focus their efforts during one of CMS’ dedicated acknowledgement testing weeks.

End-to-end testing has been a matter of some contention during the extensive run-up to the new code set, but CMS believes the three end-to-end testing sessions offered to a limited number of volunteer providers will be sufficient to prove that Medicare is ready to handle the onslaught.  “CMS is ready for ICD-10,” Tavenner proclaims in her message.

Conducting spot testing to ensure Medicare can accept and adjudicate claims does not, however, prove that the majority of healthcare providers are ready on their end to send properly encoded materials. Only providers that felt ready to conduct ICD-10 end-to-end testing at the beginning of 2015 would have volunteered for the earliest testing opportunity, so the results could be skewed towards those at the head of the class.

An ICD-10 preparedness survey released this week by Navicure found the same old mix of optimism, skepticism, fear, and weariness that has kept the new code set out of the healthcare industry’s good graces for years.  Despite mounting evidence that October 1, 2015 will be the hard and fast go-live date, close to a third of physician practices still think they will have yet another reprieve.

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Fifteen percent of physician providers have not yet started any ICD-10 preparations, with a quarter of those respondents stating that they are still waiting on software upgrades from their EHR or practice management vendors.  Thirteen percent still say that they don’t know where to start with the conversion process, and 23 percent added that they don’t feel adequately staffed to handle the complexity of the switch.


More than half of providers remain worried about how ICD-10 will impact their revenue cycles.  Forty-one percent think a lack of readiness from their payers will be the most significant challenge of the ICD-10 transition, which brings the industry right back to the critical need for comprehensive testing.  While few readiness surveys show a high degree of trust in the readiness of business partners, providers must prepare for and engage in all the end-to-end testing they can manage to ensure that the maximum number of ICD-10 claims can be adjudicated appropriately before revenue begins to depend on their success.

The Navicure survey indicates that only 11 percent of providers are already conducting ICD-10 end-to-end testing with at least one payer.  Twice as many respondents said they don’t know how or where to begin, and 10 percent stated unequivocally that they have no plans to participate in this level of testing.  If those providers were to participate in a Medicare end-to-end testing week, the results may not be so rosy.

However, the initial results from CMS can give hope to healthcare providers who have been working hard towards the deadline.  The importance of Medicare’s readiness to move forward with a 2015 implementation date should not be underestimated, especially when so many stakeholders are now pushing so hard for ICD-10 implementation before the end of the year.

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“Testing allows us to identify areas of improvement, and we will work with outside entities and stakeholders to improve those very small deficiencies identified,” Tavenner concluded. “And we will continue to do testing, especially in those areas we identify as needing improvement.  I appreciate the tremendous efforts and achievements of health professionals as we work together to realize the benefits of ICD-10 and other advances toward the ultimate goal of improving the quality and affordability of health care for all Americans.”

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