Standardizing Testing: The ICD-10 National
Pilot Program
1:30 - 2:45 PM Tuesday - June 18, 2013
Lisa Gallagher, BSEE, CISM, CPHIMS
Vice President, Technology Solutions HIMSS
Dean Cook
Infrastructure Services Sr. Advisor National Government Services, Inc.
Jim Daley
Director, IT Risk & Compliance, BlueCross BlueShield of South Carolina Chairman, WEDI
Kari Gaare
Health Insurance Specialist, Administrative Simplification Group, Office of E-Health Standards and Services, CMS
Agenda
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HIMSS/WEDI ICD-10 National Pilot Program
●
CMS End-to-End Testing Process
HIMSS/WEDI ICD-10 National Pilot Program
Learning Objectives
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Describe the ICD-10 National Pilot Program and
its purpose
●
List the program's goals, objectives and
participants
●
Discuss how the industry can utilize the
information derived from the outcomes of pilot
testing
HIMSS and WEDI co-lead the ICD-10 National Pilot Program
with the following serving as key leaders and contacts:
Leadership Team
Joe Miller
Director of E-Business AmeriHealth Mercy
Jim Daley
Director, IT Risk & Compliance BCBS South Carolina;
WEDI Chairman
Juliet A. Santos, MSN, CCRN, FNP-BC
Senior Director
Most HIT compliance initiatives of the last ten years
have been delayed!
(4010, NPI, 5010, Administrative Simplification)
●
Impact to our Industry of Delays are:
–
Increased costs to vendors, providers,
health plans and other trading partners
–
Postponed intended benefits
–
Reduced confidence in the regulatory
process
How Do We Prevent Another (Costly) Delay in ICD-10?
●
G7 Industry Leadership Meetings (April/July 2012)●
Call to Action Report (August 2012)–
Achieve Broad Stakeholder Support for an ICD-10 Pilot Program with End to End Testing of Business Processes–
Accelerate the Readiness of Vendors Supporting Health Plans, Providers, and Other Vendors–
Significantly Expand Education Focused on Independent, Physician Group Practices.–
Recognize the Cooperating Parties (CMS, NCHS, AHIMA, and AHA) and AAPC for accurate and consistent coding●
Workgroups Established●
HIMSS supports ICD-10 member education regardless of date--will support our members until completionGoals for ICD-10 Pilot Program
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Identify standard test cases that can be utilized by the general healthcare industry free of charge●
Provide early Pilot Tests that can demonstrate the feasibility of ICD-10, surface issues early, and create models for future testing●
Provide resources and guidance to providers during the implementation phase through Solutions Centers (based on successful outcomes of Pilot Phase and project funding)●
Publish incremental data on testing outcomes, best practices and to share relevant new findings●
Build collaboration among participants, build mutual trust through sharing of ideas and best practices●
Enhance the efficiency of the testing process, thus reducing the cost of “trial and error”The Testing Challenges
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Agreeing on test data
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Establishing matching
databases
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Coordinating schedules
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Conducting testing
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Validating results
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Late uptake – testing deluge
HIMSS/WEDI NPP Work Groups
Project Scope - Responsible for identifying the parameters of the
ICD-10 National Pilot Program and its work group (define what is
covered within the pilot and what is not)
Organization - Creating the structure and functions of proposed
Regional Solution Centers
Finance/Budget - Accountable for budget
development/management and funding opportunities
Testing Scenarios & Coding - Identify the test cases and receive
de-identified medical records from participants
Testing & Methodology - Develop the overall parameters for
testing
The Testing Challenge
Many to Many Relationships - Multiple Test Sets and
Schedules
PMS/HIS Vendor Vendor Provider Vendor Vendor Provider Provider Provider Provider Payer Payer Payer Payer Payer Direct Clearing house / billing servicesTesting Solution Standard
Needs to be circular relationship and include Medicare and other key stakeholders
Vendor- A/P provider Vendor Vendor Vendor Standard Test Scenarios Provider/ Practices /Physicians Provider Provider Provider Provider Standard Test Scenarios-Vendor/ Clearinghouse Payer- Medicare Payer Payer Payer Payer
Scope of Pilot Testing
●
Pilot Tests with limited “end-to-end testing” starting from patient
care to plan adjudication
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Pilot Tests Using Standard Cases
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Trading Partner Testing Using Standard Cases
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Include Medicare/Medicaid as early as possible in the pilot
testing
●
Identify Coding challenges through testing using standardized
Value of Standard Cases
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Enables a base level of testing
●
Vetted through participants
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De-identified
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Applies common threshold values
Testing Cases
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100-200 Test Cases
●
Supported with Clinical Documentation
●
Coded by experts
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Large and small providers—level of technology
sophistication and different care settings, multi
specialty/single specialty, reimbursement model
Approach to Test Case Creation
Candidate ICD-10 Test Cases Vendors Providers Payers Others ClearinghouseCollect Test Cases and Clinical Documentation Review Committee Documentation Format
Test Case
Pilot Testing
Pilot Phase – Emphasis on Clinical Relevance
Clinical
Standard Test Case Set Evolution
●
Pilot tests will offer opportunity to refine Test Cases
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Final set published on HIMSS ICD-10 Playbook site
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Can be re-used for final testing as well
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Public domain, but vendors can use them and add to
them
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Will work for large and small providers
Testing Stages
April 2013 - July 2013 August – Dec 2013 2014
Pilot Tests with Initial Test Cases
Planned effort
Test of initial standard cases Do as much end to end testing as possible, recognizing that some processes may not be finalized
Provides feedback used to refine standard cases
Independent Industry Testing with Standard
Test Cases
Standard cases used by industry stakeholders Include as many
stakeholders as possible in an end to end case
Provides feedback used to refine standard cases Cooperative Exchange Support
Full Industry Testing with Standard Test
Cases Plus Others
Additional testing test cases used by industry stakeholders as well as Standard Set Testing organized by stakeholders themselves Cooperative Exchange Support
Participating Entities
●
HIMSS, WEDI, CMS, NGS, AHIMA, AAPC, HBMA,
the Cooperative Exchange
●
There are 90 participating organizations
●
There are 218 individual participants from those
organizations
●
Those organizations represent providers,
clearinghouses, vendors, health plans, government
agencies, not-for-profits, consultants and hospitals
Progress to Date
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(To be reported at conference)
–
Participant counts
–
Current status
–
Lessons learned
●
Over 250 organizations involved
●
Test cases to be published by end of July
●
Outcomes report expected in September
timeframe
●
ICD-10 PlayBook
HIMSS ICD-10 National Testing Program Contacts
Mark Lott
President
Lott QA Group
[email protected]
Stanley Nachimson
Principal, Nachimson Advisors LLC
Co-chair, HIMSS ICD-10 Task Force, Co-chair, WEDI ICD-10 Testing SWG
UnitedHealthcare
ICD-10 Remediation & Testing Approach
Shirley Reynolds
ICD-10 Business Test Director
UnitedHealthcare, Provider Regulatory Programs June, 2013
UnitedHealth Group is committed to:
• Full regulatory compliance.
• Systems will accept new ICD-10 transactions (while continuing to accommodate ICD-9 coded claims for service dates prior to the regulatory compliance date) without data mapping or transformation.
• Perform extensive internal testing to verify predictable processing outcomes:
• Clinical Integrity: Ensure alignment with industry code mapping and consistent clinical review decisions.
• Benefit Neutrality: Ensure transparent benefit administration for members and providers across both code sets . • Revenue Predictability: Perform internal analysis and collaborate with selected external providers to assess the impact
of ICD-10 code selection on DRGs.
• Support health care providers in their readiness efforts.
• Industry assessments indicate a risk that not all providers may be ready to generate ICD-10 transactions by the compliance date. UnitedHealthcare has a dedicated communication effort to advise providers on ICD-10 preparation steps and to provide resource materials.
• Collaborate and test with providers and other business partners, including
• Testing with selected providers to identify areas at risk for unpredictable results and define strategies to improve the
accuracy and predictability of production transaction outcomes.
• End-to-end testing with limited providers, practice management/coding vendors and clearinghouses to verify transaction
compliance, accuracy and predictable payment results.
• Communicate lessons learned, mitigation strategies and readiness recommendations to our providers via portals and
other communication channels.
ICD-10 Remediation & Testing Guiding Principles
UnitedHealth Group ICD-10 Remediation & Testing Timeline
2011 2012 2013
External Partner Testing Assess & Support Vendor/ Trading Partner Readiness
Provide Readiness Outreach, Communication and Resources to Delivery-Side Partners
2014 2010
Plan Design System Build & Test Code Review, Internal Test & Readiness
External Testing & Operational Readiness
Impact Assessment
Technical Foundation & Compliance : Application Design, Development & Testing
Clinical Code Review & Loads
Comprehensive Internal Tests End-to-End and “Neutrality”
Training & Operational Readiness
Early Payer/Provider Collaboration (DRG Shift analysis)
Focus: Internal System, Staff & Process Readiness
Focus: External Business Partner Readiness Assessment, Support & Collaboration
ICD-10 External Testing Challenges
Health care organizations recognize the need to expand beyond traditional (internal) testing to include External testing with business partners, in order to understand how partner organizations will use new codes in
transactions and processing.
External testing challenges
• Requires coordination and schedule alignment between impacted parties: provider, practice management or other vendor, clearinghouse(s), payer.
• Parties must agree on test content (clinical scenarios, data, expected results). Presents challenges to identify test scenarios that:
o Represent realistic provider coding situations (based on medical records), and
o Where the expected result (correct assigned ICD-10 codes) should be pre-determined to prevent significant discovery process during testing
• Organizations must plan for resources to analyze and resolve unexpected test results. • The scope and selection of test partners may be limited. Not feasible for….
o Providers to test with all payers or Payers to test with all providers
o Practice Management/Coding Vendors, Claim Intermediaries and Clearinghouses to test with all customers
o Potential delays in organization readiness pose a risk that a high volume of partners may want to test “at the last minute” (Q3 2014).
• Manual test that allows a Facility &
Payer to evaluate coding conditions that generate an ICD-9 to ICD-10 DRG shift
• Parties agree on a sample of 100-300
ICD-9 adjudicated claims (all DRG categories)
• Facility coding staff use original medical
records to assign ICD-10 codes.
• Payer compares original claim DRG to
the DRG assigned to the ICD-10 claim.
• Claims with DRG shifts are analyzed by
OptumInsight certified coders and
• Variations are evaluated jointly by the
facility and UnitedHealthcare.
Facility- Payer Collaborative DRG Shift Analysis
Test Partners: 15-20 Key Facilities
External Testing – Phase 1 In 2012-2013, UnitedHealthcare partnered with several hospitals to
conduct early collaborative testing to evaluate potential DRG shifts
UnitedHealthcare performed internal and external analyses to predict ICD-10 coding impact on DRG Shifts, including:
• Internal high volume automated code translation and detailed analysis.
• Testing with key Facilities based on ICD-10 coding from medical records.
Preliminary Findings
• The number of clinically likely shifts was in line with CMS and 3M predictions. • As groupers are refined (v28 to v30)
DRG shifts are reducing.
• Facilities with well-trained ICD-10 coders should see comparable DRG assignments in ICD-9 and ICD-10.
Coding & Claim Payment Validation
1. Parties agree on medical records (selected from paid ICD-9 claims to provide a basis for comparison).
2. Facility or physician office assigns ICD-10 codes to test cases.
3. Payer engages clinical coding experts to also identify valid coding for test claims.
4. Test claims do not contain PHI and may be exchanged via web or secure email.
5. Payer adjudicates and returns claim payment result.
6. Provides joint visibility to code assignment and payment of ICD-10 test cases.
Limited “End-to-End” Transaction Testing
1. Tests production-like process flows (via test environments) using pre-defined medical record based test scenarios and data.
2. Requires collaboration among the
provider, vendor, clearinghouse and Payer.
3. Provider submits 837; Payer
completes test claim adjudication and returns result (835)
4. Validates accurate ICD-10 coding,
data transmission, flows , edits, and claim processing outcomes.
Test partners: selected Hospitals, Physicians, and other
providers (e.g. Home Health, DME, Lab, etc.) other providers and vendors, clearinghouses Test partners: Limited Facilities, Physicians,
External Testing - Phase 2 (2014)
In addition to participation in the HIMSS/WEDI ICD-10
National Pilot , UnitedHealthcare plans to test with
External Test Objectives
• Providers have an opportunity to practice ICD-10 coding, using real medical records, as a basis for collaborative testing.
• Provides an opportunity for payers to verify the accuracy of claim systems using ICD-10 codes selected by providers (vs. internal ICD-10 code
“mapping” assumptions).
• Assumes code selection and claim payment test results from a selection of the provider population will be extensible to all providers.
– UnitedHealthcare plans to share findings and recommendations from test efforts with all providers and business partners via provider portals and other communication channels.
End-to-End Testing for ICD-10
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Welcome
Presenters: Kari Gaare, Centers for Medicare & Medicaid Services Dean Cook, National Government Services, Inc.
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Topics
Why this project is needed
What we set out to do
What we have completed to date
What we continue to do
– Checklists (High Level and Detailed)
– Collaboration (ICPs, Listening Sessions)
– Other collaboration (CMS, HIMSS, NGS, WEDI)
More information
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Why this project is needed
Past implementation challenges
Upcoming regulatory requirements
–
Need for further clarification of terms in ACA
January 1, 2014
Compliance date for EFT/ERA standard and operating rules
October 1, 2014 Compliance date for ICD-10 December 31, 2013
and December 31, 2015
Health plans certify compliance
November 7, 2016 Compliance date for Health Plan Identifier (HPID)
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End-to-end (E2E) testing process
Regulatory requirement
Implementatio n
End-to-end (E2E) testing
• Level 1 testing • Level 2 testing • Level 3 testing Transition to production Compliance date Successful implementation
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Goals
To develop and implement a process and methodology for end-to-end testing of the transaction standards, operating rules, code sets, identifiers, and other Administrative Simplification requirements
based on industry feedback and participation.
To develop an industry-wide “Best Practice” for end-to-end testing that lays the ground work for a more efficient and less time
consuming method for health care industry testing of future
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Intended outcomes
Documents for all industry segments outlining the critical checkpoints needed to ensure compliance. Checklist drafts are published and
available and continue to be refined and published.
Universal testing process and methodology that can be adopted by all industry segments
─ Included in the checklists that continue to be refined and published.
─ Variation may occur depending on the requirement
Framework with definitions for end-to-end testing process, readiness, and compliance. Complete and published.
End-to-End Testing for ICD-10
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Welcome
Presenters: Kari Gaare, Centers for Medicare & Medicaid Services Dean Cook, National Government Services, Inc.
Proprietary and Confidential
Topics
Why this project is needed
What we set out to do
What we have completed to date
What we continue to do
– Checklists (High Level and Detailed)
– Collaboration (ICPs, Listening Sessions)
– Other collaboration (CMS, HIMSS, NGS, WEDI)
More information
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Why this project is needed
Past implementation challenges
Upcoming regulatory requirements
–
Need for further clarification of terms in ACA
January 1, 2014
Compliance date for EFT/ERA standard and operating rules
October 1, 2014 Compliance date for ICD-10 December 31, 2013
and December 31, 2015
Health plans certify compliance
November 7, 2016 Compliance date for Health Plan Identifier (HPID)
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End-to-end (E2E) testing process
Regulatory requirement
Implementatio n
End-to-end (E2E) testing
• Level 1 testing • Level 2 testing • Level 3 testing Transition to production Compliance date Successful implementation
Proprietary and Confidential
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Goals
To develop and implement a process and methodology for end-to-end testing of the transaction standards, operating rules, code sets, identifiers, and other Administrative Simplification requirements
based on industry feedback and participation.
To develop an industry-wide “Best Practice” for end-to-end testing that lays the ground work for a more efficient and less time
consuming method for health care industry testing of future
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Intended outcomes
Documents for all industry segments outlining the critical checkpoints needed to ensure compliance. Checklist drafts are published and
available and continue to be refined and published.
Universal testing process and methodology that can be adopted by all industry segments
─ Included in the checklists that continue to be refined and published.
─ Variation may occur depending on the requirement
Framework with definitions for end-to-end testing process, readiness, and compliance. Complete and published.
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Pilot definitions approved
Term Definition
End-to-end testing End-to-End testing is a focused process within a defined area, using new or revised applicable products, operating rules or transactions, throughout the entire business and/or clinical exchange cycle, for the purpose of measuring operational predictability and readiness. The End-to-End testing process should be performed in an environment which mirrors actual production as closely as possible, confirming the validation of performance metrics and analytics (reporting).
Readiness Readiness is a state of preparedness in which an Entity has completed
verification and validation of applicable policies, procedures, guidelines, laws, regulations, and contractual arrangements with expected results. Additionally, entities will demonstrate readiness by completing internal documentation, establishing communication mechanisms and validation with external trading partners, training of appropriate personnel , scheduled deployments, and software migration for each regulatory requirements.
Compliance Demonstrated adherence to those policies, procedures, guidelines, laws, regulations to which the business process is subject in advance of, by or after the regulatory implementation date.
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Levels defined
Level Explanation of purpose
1 The period during which entities perform all of their internal readiness activities in preparation for testing the new versions of the standards with their Trading Partners. When an entity has attained Level 1 compliance, it has completed all internal readiness activities and is fully prepared to initiate testing of the new versions in a test or production environment, pursuant to its standard protocols for testing and implementing new software or data exchanges.
2 The period during which entities are preparing to reach full production readiness with Trading Partners. When an entity is in compliance with Level 2, it has completed some end-to-end testing with external Trading Partners. Key difference between Level 1 and Level 2: Level 2 is done in a
“production-like” environment that may not be exactly a replicate of the production system.
3 The period during which end-to-end testing is performed with external Trading Partners and the Trading Partner is able to operate in production/production-like mode with the new versions of the standards by the end of that period. By ‘‘production/production-like mode”, we mean that entities can successfully exchange (accept and/or send) standard transactions and, as appropriate, be able to process them successfully. Key difference between Level 2 and Level 3: Level 3 is conducted in
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Levels and Elements assigned
Transition
Planning Assessment Design Development Testing Transition Level 1 is the period during which entities perform all of their internal readiness activities in preparation for testing the new versions of the standards with their Trading Partners. When an entity has attained Level 1 compliance, it has completed all internal readiness activities and is fully prepared to initiate testing of the new versions in a test or production environment, pursuant to its standard protocols for testing and implementing new software or data exchanges.
Assessment Design Testing Transition
Level 2 is the period during which entities are preparing to reach full production readiness with Trading Partners. When an entity is in compliance with Level 2, it has completed some end-to-end testing with external Trading Partners. Key difference between Level 1 and Level 2: Level 2 is done in a
“production-like” environment that may not be exactly a replicate of the production system.
Planning Testing
Level 3 is the period during which end-to-end testing is performed with external Trading Partners and the Trading Partner is able to operate in production/production-like mode with the new versions of the standards by the end of that period. By ‘‘production/production-like mode,’’ we mean that entities can successfully exchange (accept and/or send) standard transactions and, as appropriate, be able to process them successfully.
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Industry segments
At this time there are five industry segments being addressed in this project.
Small Provider
Large Provider
Payer
Vendor-to-Payer
Vendor-to-Provider
These industry segment checklists are all in continuous development and revision.
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High level documents
The High Level End-to-End Testing Documents provide more of an overview than the “detailed” checklists.
There are two high level documents created for each industry segment (ICD-10 and Administrative Simplification).
Each High Level End-to-End Testing Document includes a Process Flow chart as a visual aid for the user.
These documents are available from the CMS End-to-End Testing web page located at http://www.cms.gov/Regulations-and-Guidance/HIPAA-
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Detailed checklists
The “detailed” checklists are Excel workbooks. Each identified industry segment has a detailed checklist.
Within the detailed checklists there are tabs for each of the following:
Instructions
Definitions
Initial Assessment checklist
Administrative Simplification checklist
ICD-10 checklist
Testing Guidance checklist
These checklists are available from the CMS End-to-End Testing web page located at
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Industry Collaborative Partners (ICPs)
Aetna*
American Health Insurance Plans (AHIP)* American Hospital Association (AHA) American Medical Association (AMA) CMS Medicaid
CMS Medicare Fee For Service Emdeon
Healthcare Billing & Management Association (HBMA) IVANS
Medicaid – CSG Government Solutions
Medical Group Management Association (MGMA) Nachimson Advisors, LLC
Providence Health and Services TIBCO Foresight
TRICARE
UNC Health Care Walgreens
WellPoint
Veteran’s Affairs * Count as one ICP.
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ICP Webinars
Participation by invitation; there are 18 ICPs
Weekly or semi-weekly webinars (Tuesdays and Thursdays) as needed
Review and input forum for the following:
– Checklists
– Related materials
– Q&A from mailbox, webinars, and other special presentations
# Sessions # ICPs Avg # registered Avg # attend % Reg vs. attend
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Listening Sessions
Weekly or semi-weekly webinars (Tuesdays and Thursdays); more sessions and other days as needed to meet demand
Open sessions; invitation requests via email to [email protected]
NGS presentations with Q&A session following
All registered attendees receive a copy of the presentation and the related checklists via email; the checklists are also available on the CMS End-to-End Testing web page
Listening Sessions are on a break until July 2013 to allow the team to incorporate feedback and suggestions
Upcoming sessions will be listed on the CMS End-to-End Testing web page.
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Listening Sessions
Listening Sessions # Sessions to date Total attendance Average attendance
Small Provider 14 963 69 Large Provider 12 1,128 94 Vendor 12 764 64 Payer 9 765 85 Special sessions 3 302 101 Total 50 3,922 78
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Other outreach
Questions, comments, and requests via email
NGS Surveys
– Round 1 – January 2013 – Round 2 – March 2013
NGS Listening Session Real Time Polls
– Began April 16, 2013
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Collaboration
CMS/NGS and HIMSS/WEDI collaboration
CMS materials will be included in HIMSS/WEDI ICD-10 National Pilot Program
HIMSS/WEDI participants will review and provide feedback on the checklists
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Differences
CMS/NGS and HIMSS/WEDI processes
CMS/NGS is developing definitions and a description and framework of end-to-end testing for all Administrative Simplification
requirements, including ICD-10
HIMSS/WEDI is an actual application of testing specific to ICD-10
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CMS End-to-End Testing Pilot
What it does NOT include.
A software package or application that will create test claims for the industry
Test data to be used by the industry
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CMS/NGS timeline
NGS Pilot for End-to-End Testing
Phase I – Business and Gap Analysis - September 24, 2012 through December 21, 2012 (Complete)
Phase II - Development of Pilot Testing (Artifacts, Definitions,
Process and Methodology) - December 10, 2012 through June 27, 2013 (approximately six months)*
Phase III - Implementation and Quality Assurance is July 1, 2013, and will run through September 23, 2013 (approximately three months)*
HIMSS ICD-10 National Pilot Program
Early Phase – April 2013 through July 2013 Second or Middle Phase – August 2013 through December 2013 Third or Late Adopter Phase – January 2014 through June 2014
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CMS ICD-10 web page located at http://www.cms.gov/Medicare/Coding/ICD10/
CMS End-to-End Testing web page located at http://www.cms.gov/Regulations-
and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/End-to-End-Testing.html has links to all the checklists.
CMS Email Updates (CMS ListServ) feature is available
on all CMS web pages. Submitting your email address ensures notification of CMS updates including End-to-End Testing checklists and other related documents.
Medscape Education modules link is available from the CMS ICD-10 web page
(https://login.medscape.com/login/sso/getlogin?urlCache=aHR0cDovL3d3dy5tZW
RzY2FwZS5vcmcvdmlld2FydGljbGUvNzY1NzU0&ac=401). Note that “Continuing
medical education (CME) credits are available to physicians who complete the modules, but anyone can take them and receive a certificate of completion.”
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Contact information
All questions may be sent to [email protected]
– Our expected level of service is to respond within one business day
Additional contact resources . . .
Resource Role Email addresses Work phone Cell phone David Carrier Lead BA [email protected] (207) 253-1203 (207) 210-2340
Dean Cook Advisor/SME [email protected] (502) 889-4762 (502) 376-6510
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