WEDI Strategic National Implementation Process (SNIP) ICD-10 Testing Sub Workgroup Issue Brief ICD-10 Vendor Readiness July 16, 2015 Workgroup for Electronic Data Interchange 1984 Isaac Newton Square, Suite 304, Reston, VA. 20190 T: 202-618-8792/F: 202-684-7794
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Table of Contents Purpose and Scope... 4 Target Audience... 4 Vendor ICD-10 Considerations... 5 1. Communicate ICD-10 FAQs... 5 2. Vendor System Environment / Access Considerations... 6 3. Documentation and Communication... 7 4. Issue Tracking and Resolution... 7 5. ICD-10 Testing Lessons Learned... 7 6. ICD-10 Production Submission Requirements... 8 7. ICD-10 Related Fee Changes... 8 8. ICD-10 Readiness and Contingency Planning... 8 9. ICD-10 Links to Industry Websites... 8 WEDI Resources... 10 Summary... 10 Acknowledgements... 10 WEDI ICD-10 Testing Workgroup Page 3
Purpose and Scope This WEDI issue brief provides a list of items that System Vendors should address regarding the ICD-10 remediation, testing, and implementation of their products. Communicating the items identified in this issue brief will help to provide greater transparency and insight into a Vendor system s ICD-10 readiness. Vendors should work with their Customers concerning: special system considerations; overall timing; testing; training; system installation; implementation and post-implementation support. Vendor communication regarding their ICD-10 preparation, transition plan, and post-implementation support will both alleviate Customers readiness concerns and provide instruction for their Customers use of the Vendor s remediated product. Proactive guidance will help Customers avoid confusion and provide a smooth transition to the ICD-10 coding environment. ICD-10, which will replace ICD-9 code sets and update ICD-9 terminology, consists of two parts: (1) ICD-10-CM will be used for diagnosis coding of symptoms or causes of injury or disease; and (2) ICD-10-PCS will be used for coding of inpatient procedures. ICD-10 does not affect CPT coding for outpatient procedures and physician services. The compliance date is October 1, 2015. Target Audience The authors intend that Vendors of the following systems or services will find this Issue Brief useful in their ICD- 10 preparation: HIS (Hospital Information Systems) PMS (Practice Management Systems) EHR (Electronic Health Records) Transaction Clearinghouses Any other third party hardware/software used in the clinical or revenue cycle process Some detail items may not apply to each Vendor s offering; however, consideration of each item is recommended so that Vendors can confirm each unique product or service has been appropriately remediated to support the ICD-10 codeset environment. WEDI ICD-10 Testing Workgroup Page 4
Vendor ICD-10 Considerations 1. Communicate ICD-10 FAQs ICD-10 frequently asked questions (FAQs) should be available to answer the most common Customer questions about a Vendor's ICD-10 program. FAQs provide insight into the Vendor s remediation and testing approach, address questions specific to each product or service offering, and include the Vendor s overall timeline for deployment of their ICD-10-ready products. FAQs could address the following topics and questions: Preparation FAQs: What has Vendor done to prepare for ICD-10? Does the Vendor s system require native coding in ICD-10; otherwise, what mapping or crosswalk strategy is used between the old and new code sets? What is the Vendor s approach for ICD-10 compliance? What is the Vendor s plan for communicating progress and expected product availability dates? When will the Vendor begin accepting ICD-10 transactions? Are there any new screens or reports in the Vendor s system that Customers may use to gain familiarity with the ICD-10 codes? Has the vendor considered the need to submit claims with ICD-9 codes to non-covered entities who are not required to use ICD-10? Does the Vendor provide implementation planning or support services? Testing FAQs: What was the Vendor s approach to testing their system, and what kind of testing was performed? What were the Vendor s external testing results and how do you plan to share them? What were the lessons learned from testing? Is the Vendor accepting testing requests? Does the Vendor offer End-to-End testing, and if so, with which payers? Can the Vendor s system intake a test 999 or 277? Does the Vendor s system support the ability to send ICD-10 Test Files? Does the Vendor s system support the ability to receive ICD-10 Test Files? Can the Vendor s system intake a test 835? Will the 835 remittance advice be returned to the Customer as part of End-to-End testing? Whom do I contact and how do I obtain information on how to test using the Vendor s system? Claim FAQs: When will the Vendor s system accept ICD-10 claims? Will the system accept both ICD-9 and ICD-10 claims after 10/1/15, to allow for the submission of claims to non-covered entities not using ICD-10? How long will it accept ICD-9 claims? Will the system accept or reject claims that contain both ICD-9 and ICD-10 codes? How will the system handle claims with dates of service that span the compliance date? Will the system allow Customers to submit both ICD-9 and ICD-10 claims for dates of service or dates of discharge after the cutover date? WEDI ICD-10 Testing Workgroup Page 5
Will the system accept unspecified codes? Other ICD-10 FAQs: What communication do you provide to Customers about ICD-10 changes? ICD-10 overview what does it impact in your system? Will the Vendor s system use a crosswalk in processing transactions? If so, what was your approach to mapping ICD-9 to ICD-10 codes? Will there be any changes to the pre-authorization submission process? When will you accept ICD-10 pre-authorization requests for services provided on and after 10/1/15? Will pre-authorizations submitted before 10/1/15 that use ICD-9 codes work for ICD-10 claims? Will your system support ongoing use of ICD-9 codes? How may a Customer identify payers who will continue to require ICD-9 codes? How will you help prepare Customers for transition to ICD-10? Where can Customers find more information about ICD-10? 2. Vendor System Environment / Access Considerations Vendors should address the following issues in the preparation of their ICD-10-compliant products, and inform their Customers when they have been completed or are ready for deployment in the Customer s environment. Communicating the status of these issues will improve Customer awareness of the Vendor s preparations and demonstrate whether the Vendor s products will be ready for the scheduled ICD-10 compliance date. Publish a timeline for Customer testing and implementation of new software Verify the Vendor s server preparation is complete Verify the Vendor s software has been successfully remediated to process the ICD-10 codeset Verify any required Vendor database setup is complete Verify the Vendor s database has been updated to include the complete ICD-10 codeset Confirm Customers are able to access the Vendor s test system (via web portal or proprietary gateway) Confirm submission protocols are operational (SOAP/WSDL, Mime/Multipart) Verify the same edits are in place in both the Customer test and the production versions of the Vendor system Verify any dummy compliance date used in the Vendor s test system correctly accepts/rejects ICD-9 vs. ICD-10 coded transactions Verify Customers are able to submit ICD-10 test claims and inquiry transactions to the Vendor s test system, and receive a correct response Verify generation and delivery of the 835 remittance advice, if provided to the Customer Verify any final ICD-10 software revisions, or scripts needed to resolve discrepancies in the Vendor s test system, have been applied to the Vendor s production system Perform response time testing of the remediated system Perform load testing (transaction volume testing) under simulated production conditions Verify final ICD-10 revisions are implemented in the Customers version of the Vendor s system Advise Customers on how to determine if any system upgrades are outstanding and how Customers should work with the Vendor to develop a plan for remediation WEDI ICD-10 Testing Workgroup Page 6
3. Documentation and Communication Provide an overview of the Vendor s ICD-10 program, including an outline of objectives and scope and a description of the Vendor s approach to ICD-10 testing with Customers and Payers. Explain how ICD-10 revisions impact the Vendor s system, and what the Vendor has done to prepare for the transition to ICD-10. Provide information and helpful resources for Customers to use in preparation for the ICD10 transition, and explain the specific actions Customers can take to prepare for implementing the Vendor s remediated system. Suggestions on how they can most easily train or help their staff adapt to changes required in the Vendor s new system will also aid in the Customer s transition to ICD-10. Details should include the following: Advise Customers on any special requirements for identifying and submitting test claims to the Vendor and whether special claim-submission procedures need to be addressed for production submissions after the compliance date Define expectations for Customer testing and explain how Customers are to communicate and perform analysis with the Vendor on test results Specify the compliance date the Vendor plans to use for testing purposes Describe how the Customer can compare payment results generated from ICD-10 testing with payments the Customer has received using ICD-9 Publish the Vendor s plan for communicating progress, and what information the Vendor will provide to Customers Describe internal and functional testing already completed in the Vendor s system; include results achieved from Customer and Payer testing Provide ICD-10 test instructions to Customer organizations; explain if a "dummy" compliance date is used in the Vendor's Test system, and how the Customer is to identify test files and transactions Explain the testing information the Vendor will provide to Customers Provide the production testing and implementation timeline for the Vendor s remediated system 4. Issue Tracking and Resolution Publish step-by-step instructions and detailed participation requirements to guide Customers on how to successfully engage in ICD-10 testing with the Vendor, and how the Customer is to report any discrepancies encountered. Explain what Customers should expect regarding issue resolution and announcements related to implementing the Vendor s system. Clarify Customer expectations for testing and implementation support Provide Customers with issue reporting instructions and contact information (Vendor hotline, incident reporting email address, and contact personnel) available for reporting any discrepancies found during testing or implementation of the Vendor s system Instruct Customers on the issue tracking process and how Customers will be informed of evaluation, tracking, and resolution of discrepancies 5. ICD-10 Testing Lessons Learned Communicate and share any ICD-10 testing lessons learned so that others may benefit from the Vendor s testing approach, engagement, and experience. Provide information on the following: What worked well? What testing aspects were challenging and more complex than initially planned? WEDI ICD-10 Testing Workgroup Page 7
What were the lessons learned from ICD-10 testing? How will final testing results be communicated? 6. ICD-10 Production Submission Requirements Communicate any transaction-level production submission requirements for applicable transactions. Specify cutover-date requirements, as well as ongoing post-cutover requirements related to the ICD-10 transition; and explain where ICD-10 does not affect specific transactions or system functions. Requirements should include: Dates of service / discharge requirements for claims that span the compliance date Diagnosis code level of specificity requirements Requirements to include external cause codes Institutional claim bill type requirements Real-time eligibility, prior authorization, and/or referral authorization requirements Specific ICD-10 edits that have been created Use of ICD-9 codes for non-covered entities not moving to ICD-10 7. ICD-10 Related Fee Changes Communicate fees associated with remediated products or support services. Clearly indicate if the changes are related to ICD-10 or not. If no changes are planned, communicate this to clearly set Customer expectations and minimize questions / concerns. 8. ICD-10 Readiness and Contingency Planning Provide information about the Vendor s system readiness and contingency planning, and an announcement of a production system availability date, to assure Customers the Vendor has completed technical remediation of all applicable systems and is ready to support ICD-10. Vendor information should address the following questions: How will the Vendor communicate any issues with ICD-10? What plans does the Vendor have in place to respond to any implementation issues that may arise? Who should the Customer contact if experiencing implementation problems? Will any special support be offered to Customers for issues / questions about claims submission or payment? 9. ICD-10 Links to Industry Websites The following links to industry and trading partner ICD-10 websites may serve as a helpful resource for Vendors and their Customers in their preparations for the transition to ICD-10. Centers for Medicare and Medicaid Services (CMS): www.cms.gov/icd10/ CMS "Road to ICD-10" website for small practices: www.roadto10.org Workgroup for Electronic Data Interchange (WEDI): www.wedi.org/topics/icd-10 American Health Information Management Association (AHIMA): www.ahima.org/icd10 American Academy of Professional Coders (AAPC): www.aapc.com/icd-10/ WEDI ICD-10 Testing Workgroup Page 8
WEDI ICD-10 Testing Workgroup Page 9
WEDI Resources Vendors and their Customers will also find helpful guidance in ICD-10-related Work Products available on the WEDI website at www.wedi.org/topics/icd-10, including: ICD 10 Testing for Small Providers Ten Items That Payers Should Share on Their ICD-10 Website Summary Providing information on ICD-10 readiness is a powerful component in creating the atmosphere of collaboration and transparency needed to succeed both in the testing and deployment of ICD-10-CM and ICD-10-PCS compliant products. Testing internally and externally helps both Customers and Vendors confirm their preparedness for the shift to ICD-10 by enabling them to validate updated business procedures and Vendor system changes. Identifying potential areas of concern in advance of the cutover, such as a need for new system use instructions, allows Customers and Vendors to review and correct processes and documentation to minimize possible impact on production workflow or revenue following the planned ICD-10 implementation on October 1 st, 2015. Acknowledgements WEDI ICD-10 Testing Workgroup Co-Chairs: Rob Gibran, Cognosante Stanley Nachimson, Nachimson Advisors Crystal Ewing, ZirMed The co-chairs wish to express their sincerest thanks and appreciation to the members of the ICD-10 Testing Workgroup who participated in the creation of this document. Crystal Ewing, ZirMed Maureen Randall, CompuGroup Medical Charles Veverka, Kunz Leigh & Associates WEDI ICD-10 Testing Workgroup Page 10