CMS Touts Recent ICD-10 Testing as Successful Despite Low Turnout

875 Participants out of  434,163 Affected Providers

The 2-page report by CMS gives percentages without any context, and disregards the fact that so few providers participated in the tests.

The 2-page report by CMS gives percentages without any context, and disregards the fact that so few providers participated in the tests. Click the image to download a PDF of the report.

The most recent ICD-10 tests of claims submissions to Medicare revealed  improved acceptance rates compared to January’s tests, according to the Centers for Medicare and Medicaid Services (CMS). Nevertheless, the number of participants is still quite meager, give the universe of providers who submit 4.4 million claims daily, worth more than $1 billion.

What their report fails to mention is that only 0.2% of all affected providers have been tested:

875 tested versus 5,685 facilities plus 428,478 physicians.

And those numbers (of all affected providers) are perhaps drastically underestimated. According to the Medicare News Group, CMS has more than one million providers and suppliers and receives 18,000 new requests each month from providers and suppliers who want to join Medicare. If we use the one million number, then only 0.0875% have tested. Spelled out, that’s less than one tenth of one percent. Those figures get even worse if we insert CMS’ own number, 1.5 million distinct providers and suppliers: only 0.058% have tested.

Prepared for… what?

Be prepared, not only for the October 1 date, but also for the time before then.

Be prepared, not only for the October 1 date, but also for the time before then.

Based upon these tests, to think that the industry or even CMS is ready for the transition to ICD-10 is absurd. (And don’t even think about whether those submitted claims will even be paid, even if they are received. Remember there has been ZERO testing of such claims for surviving audit – or more realistically, the RAC auditors.)

If NASA were to take this approach, then they could claim that we are perfectly ready to safely and successfully complete manned missions to Mars (a 1,400,000 mile trip), because they have safely and successfully orbited the Earth (a 25,000 mile trip), which is just 0.2% of the distance to Mars.

Even so, I wouldn't bet on the Kanye West to succeed in this.

Even so, I wouldn’t bet on the Kanye West to succeed in this… whatever it is…

The chances of CMS’ success, based upon these numbers, seem as likely to succeed as Kanye West opening a School of Charm, or Donald Trump running for President.

We shall refrain from comparing the “success” of the launch of Healthcare.gov, but that experience tends to lurk in the recesses of our minds, yes?

Data with No Context

Data, but no context = Danger

Data, but no context = Danger

Data released on June 2 showed an increase in test claims submitted and a decrease in the percentage of errors related to diagnosis codes, CMS announced in a statement. Healthcare providers, clearinghouses, and billing agencies, as well as Medicare administrative contractors (MACs) and the durable medical equipment suppliers, and MAC Common Electronic Data Interchange (CEDI) contractors were participants in the new round of tests, which ran April 27 to May 1, yielding the following results:

  • 23,138 test claims received
  • 20,306 test claims accepted
  • An 88 percent acceptance rate
  • 2 percent of test claims rejected due to invalid submission of ICD-10 code

Let’s Add Some Context

Hard to know what this means without context... uh... maybe the kitty had a weapon?

Hard to know what this means without context… uh… maybe the kitty had a weapon?

Other “rejections” that occurred were supposedly due to errors unrelated to ICD-9 or ICD-10, including incorrect NPI, Health Insurance Claim Number, or Submitter ID; dates of service outside the range valid for testing; invalid HCPCS codes; and invalid place of service. However, if 12% of claims were rejected in total (100% – 88%), and 2% were rejected for invalid ICD-10 codes, then that leaves 10% rejected for “unrelated” reasons. And if the normal FFS Medicare claims acceptance rates average 95-98 percent, then why this suddenly large error rate not related to the coding? A 10% “unrelated” error rate is two to five times the “normal” error rates. CMS neither mentions nor addresses this large issue.

Relativity & Scale

A mustard seed in my hand is insignificant, but in my eye would be significant. So where does ICD-10 fall in this world?

A mustard seed in my hand is insignificant, but in my eye would be significant. So where does ICD-10 fall in this world? And how can such a small “improvement” in the ICD-10 Testing be considered “significant” unless it is only compared to the massive failure that is the previous testing participation?

According to The Coalition for ICD-10, an ICD-10 advocacy group, half the claims submitted for this round of testing were professional claims, showing “significant” progress since the January tests.  Significant?

Webster’s Dictionary defines “significant” as, “sufficiently great or important to be worthy of attention; noteworthy.

Apparently, I’m not using the scale as The Coalition.

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