CMS Remains Committed to Providing Additional Resources to Help States Get Ready

Yesterday, I was at the HIMSS G7 where we focused on the ICD-10 PlayBook, Version 2. During the session, we hosted the national ICD-10 stakeholders (national associations and Centers for Medicare and Medicaid Services) to discuss 5010 readiness issues. Joe Miller, former chair of the HIMSS Medical Banking and Financial Systems Committee, led a special call-out session with them.

I’ve documented some of the dialogue in a question/answer format:

Q. What will CMS do at the central office level to monitor how things are going since concern exists that there will be claims not being paid, and thus, providers can’t exist for a long time in that way? Will CMS step in?

A. CMS is surveying providers, clearinghouses and payers; they have received over 500 responses and are expecting to report the results when closer to a statistically significant response rate. CMS also is seeking help from associations on getting the word out on the survey, and hopes associations will encourage members to participate. CMS values  additional information from associations to assess roll-out and it may hold with this group again to do this.  

Joe Miller, former chair of the HIMSS Medical Banking and Financial Systems Committee, leads ICD-10 stakeholders in a session at the HIMSS G7 at the Vanderbilt Center for Better Health in Nashville, Tenn., on Nov. 9.

Q. What percentage of transactions are 5010 that MACs, the Medicare Administrative Contractors who manage the Medicare program at the regional levels, are seeing today?

A. Approximately 6.8 million and 10.8 million cross-over claims have come through production. The numbers are still low, and CMS does notice that the 835, version 5010, remittance transactions seem a real problem. We also are seeing post office and zip code issues in the claims process. 

Q. The MAC numbers are very low, and there are concerns about disruption to the provider’s revenue and how this will impact the providers and their patients. Is it possible to let commercial plans continue to process 4010? For example, the Blue Cross / Blue Shield Association issued a request for a 90-day extension.  

A. CMS is aware that BCBSA requests a 90-day extension (letter submitted yesterday), however, commercial plans are required to abide by the Jan. 1, 2012, date for full conversion to the 5010 version of the transactions.

Q. In processing claims, Medicare is using provider enrollment information instead of the address used on the claim. Are they rejecting these?

A. CMS is investigating this issue to see if they are being rejected.

Follow-up response: Per a large clearinghouse, CMS is rejecting these claims, and it is an ongoing problem.

Q. What enforcement will be in place?

A. CMS processes all complaints like any other complaint; if there is reason to believe non-compliance, CMS will work with groups and seek a corrective action plan. Previously, CMS has been somewhat lenient; however, CMS is implementing a maximum 6-month window for compliance, if they choose to do so, after which, CMS expects compliance.

Q. If a provider sends a non-compliant transaction to a non-compliant state plan (4010), such as would be the case with Medi-Cal based on its public statement they would not be compliant by January 1, 2012, would both the provider and the plan then be out of compliance?

A. CMS agrees that both are non-compliant in this hypothetical scenario. CMS is working with plans and providing resources to help them to reach full compliance by the federally mandated date of Jan. 1, 2012.

Q. Has CMS had any discussions about mitigating issues with cross-claims processing?

A. CMS will respond to these issues, particularly, as they pertain to Jan. 1, 2012, being the start of the New Year, and a time when Medicare beneficiaries are meeting their deductibles. That’s when Medicaid kicks-in for those beneficiaries. 

Q. Is there a major CMS announcement planned in November?

A. CMS intends to share the results of its industry readiness survey in late November, but no major announcement is now planned.

Let us know your questions on ICD-10 compliance. Share them here on the HIMSS Blog.