The California Medical Association (CMA), American Medical Association (AMA), and 98 other state and specialty societies urged the Centers for Medicare and Medicaid Services (CMS) to put contingency plans in place for the October transition from ICD-9 to ICD-10 to avoid possible failures that could result in significant disruptions for physicians and Medicare patients. Now that CMS and the chairmen of the three Congressional health committees have announced they will not support a further delay in the implementation of ICD-10, organized medicine has turned its attention to CMS to institute protections for physicians.   

According to a recent end-to-end testing by CMS, if ICD-10 were implemented today, claims acceptance rates would fall from 97 percent to 81 percent, which could cause a catastrophic backlog of millions of unpaid Medicare claims. In their letter, CMA and other groups argued that the actual acceptance rate for claims could actually be much worse because those physicians that participated in the testing are better prepared for the ICD-10 transition than many of their peers. CMA, AMA and the other groups are asking CMS to conduct end-to-end testing in all modes of practice for a larger sample of physicians and to publicly release the results. Moreover, the groups are asking CMS to provide advance payments to physicians in the event that claims are delayed. 

“The likelihood that Medicare will reject nearly one in five of the millions of claims that go through our complex health care system each day represents an intolerable and unnecessary disruption to physician practices,” said AMA President Robert M. Wah, M.D. “Robust contingency plans must be ready on day one of the ICD-10 switchover to save precious health care dollars and reduce unnecessary administrative tasks that take valuable time and resources away from patient care.”

The group says that quality programs will also be impacted by the transition to ICD-10 and have asked CMS to also consider that while reporting periods are based on the calendar year, the switch to ICD-10 will be occurring more than three quarters of the way into the year. This could be problematic for quality reporting measures that capture encounters pre-and post-visit for those services that straddle the October 1 transition deadline. Difficulties may arise in situations where physicians will be required to report ICD-9 codes for the first segment of care, but ICD-10 codes for the final. Therefore, the  groups have asked CMS to mitigate the impact of ICD-10 on quality reporting programs. 

CMA is separately urging CMS to delay implementation if the results from the end-to-end testing is not successful for at least 95 percent of physician claims. The group said it is concerned the “administration is underestimating the impact the transition to ICD-10 will have on the regulatory tsunami that is already burdening physicians and threatening access to quality care.”

Click here to read the letter.