Testing Is the Key to ICD‐10 Readiness‐and Contingency Planning

February 24, 2014

We’re entering the heart of the ICD-10 testing period. Whether your organization is well into the process or just beginning it, now is the time to assess your testing plan to ensure that it’s comprehensive-and that you’re ready to incorporate the results into your contingency planning.

Regardless of where you are in your testing process, you should also prepare for the upcoming ICD-10 testing week with Medicare Administrator Contractors (MACs), to be held March 3-7, 2014. Although the Centers for Medicare & Medicaid Services (CMS) will not be implementing full end-to-end testing, they have mandated that all MACs offer providers an opportunity to submit test claims through the Common Edits and Enhancement Module (CEM) or the Durable Medical Equipment (DME) Common Electronic Data Interchange (CEDI). Take advantage of this opportunity-there may not be another.

Of course, testing with MACs is just one piece of the process. The tips below will help you approach each phase of testing the right way. The results will reveal any gaps in your training or technology, enabling you to craft an informed contingency plan that makes the best use of your available resources.

Continue to Measure Improvement as Go-Live Approaches
By this point, coders and physicians should have received some training on the changes that ICD-10 entails. Yet they may still be unfamiliar with the changes to their workflow, and unaccustomed to the new codes and processes.

Measuring your coders’ productivity and accuracy on an ongoing basis between now and go-live will provide a clearer picture of the impact ICD-10 will have on coder productivity and physician documentation requirements, and help keep your contingency plans rooted in reality. And taking steps now to boost ICD-10 productivity and accuracy among your staff will minimize the need to bring on additional staff or outsource ICD-10 coding responsibilities after the deadline.

What steps might those be?

Here’s one recommendation that might surprise you: hire temporary or outsourced staff now-to handle some or all of your ICD-9 coding while your own staff learns to code fluently in ICD-10, so they’re ready when the go-live hits.

After go-live, expert ICD-10 coders will be a scarce, much-sought-after (and expensive) resource. Your staff being unprepared to code claims in ICD-10 could lead to a spike in denials due to inaccurate coding, or a backlog due to low productivity that builds and builds-and by that point there might not even be any ICD-10 coders available to help.

At a bare minimum, identify your slowest day of the week, then ask your staff to code one or two of your most common claim types in ICD-10 on that day. Adding these one or two claims per week will help them become more familiar with the codes and will lay a good groundwork for transitioning to ICD-10.

Application and Integration Testing
As you begin testing individual applications, ensure that each and every error or glitch is documented and logged.

It’s crucial to compile a comprehensive, regularly updated list of existing issues and whether or not they’ve been resolved. Why? As you implement integration testing-that is, testing how well your internal applications work together-and then expand that testing to include external systems, you need to be able to see at a glance any errors that could affect the transfer of data between these applications and systems. This will help you identify where exactly the problem lies, and whether an impending fix to an individual application could resolve the integration and interoperability issues.

A few tests and outcomes are particularly important.

For individual applications:

  • Does your practice management system produce an ICD-10-compliant 837?
  • Do your applications support dual coding? (There will be instances when you need to encode some claims in ICD-9 and others in ICD-10.)

For integration testing:

  • Does your practice management system successfully send the ICD-10-compliant 837 to your clearinghouse?
  • Can your clearinghouse confirm the transmission of 837s to payers?
  • Is all the data flowing to downstream applications? If not, where are the holes in the pipeline?

Integration testing will reveal potential weaknesses in your vendors’ preparation and testing-track those, too. If the issues you find aren’t resolved in the coming months, identify alternate vendors who can become part of your contingency plan.

Most Major Payers are Ready for Testing Now
Now the challenge becomes coordinating and scheduling your testing with payers-and making sure you mine the results for strategies to minimize rejections post go-live. These tests will also give you the best gauge of potential financial impact due to rejections.

Your clearinghouse may be able to help with this portion of the testing. In addition to providing training and educational resources, ask whether your clearinghouse can:

  • Facilitate end-to-end testing with your most critical payers-if those payers support end-to-end testing
  • Provide a testing environment that allows you to submit ICD-10-encoded claims
  • Track and incorporate ICD-10 payer validations
  • Identify problems that lead to claims being rejected
  • Provide guidance on how to fix the rejections caused by the ICD-10 transition

Wherever possible, coordinate with your clearinghouse so you both move in lockstep while testing with your critical payers. Don’t delay making contact-the payer’s availability for testing with your clearinghouse may be one-time-only, and you don’t want to miss your opportunity!

Testing with your clearinghouse will provide insight into their preparedness and willingness to help you with the transition. Those are critical considerations as you begin your contingency planning-if your clearinghouse isn’t up to the job, now is the time to find out, so you can look for alternatives before it’s too late.

Turning Test Results into Next Steps
Be sure to take advantage of the coordinated testing initiatives and your vendors’ online testing environments. And remember, ICD-10 testing is more than just checking items off a list. It’s the best way to fully map your organization’s preparedness for go-live-and it’s the only way to create workable contingency plans tailored to your organization’s unique needs.

Betty Gomez is director of Regulatory Strategy, ZirMed.

Testing Is the Key to ICD‐10 Readiness‐and Contingency Planning

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