CMS is constructing web addresses for SNF Quality Reporting initiatives, PBJ, etc.

CMS has opened web links (some are still "under construction"  as of today)  here, on it's Nursing Home Quality Initiative Page.  If you scroll down the links on the left-hand side, you'll find at the bottom links for:

SNF Quality Reporting
SNF Quality Reporting Reconsideration and Exception and Extension
Staffing Data Submission PBJ

Looks like a page to bookmark and check frequently

Memo to Long Term Care Facilities on Disenrollment Issues (05/26/15): Warning us of consequences for dis-enrolling beneficiaries without their knowledge or consent

CMS has released a Memo to LTC Providers warning us of consequences if we can't prove that we did not dis-enroll a beneficiary without their knowledge or consent.  For those of you in MMP dual-eligible demonstration states - California, Illinois, Massachusetts, Michigan, New York, Ohio, South Carolina, Texas, and Virginia - they call us out on MMP dis-enrollment, too:

0. CONSEQUENCES OF BENEFICIARY DISENROLLMENT BY A LTC FACILITY
   If documentation of a beneficiary’s request to change enrollment cannot be provided by a LTC facility, CMS will consider the enrollment not to be legally valid, cancel the enrollment action and, if necessary and appropriate, reinstate the beneficiary’s MA, MAPD or MMP coverage as if never disenrolled (Medicare Managed Care Manual, Chapter 2, Sec. 40.6). CMS will be reporting these incidents to the Medicare Drug Integrity Contractor (MEDIC) that investigates fraud and abuse incidents. 
   
   
   

Payroll Based Journal (PBJ) Software Developer/Vendor Call Minutes

Payroll Based Journal (PBJ) Software Developer/Vendor Call Minutes  Click here to read the minutes of the vendor call for PBJ.  This is the presentation of the software requirements specifically for software vendors.  It does not discuss CMS policy.  It does go into great detail on what will be required for mandatory and voluntary transmission of staffing data.  The transcript of minutes lists the following as important resources for vendors:

Important Resources
CMS.gov - PBJ Quality Reporting
http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/NursingHomeQualityInits/Staffing-Data-Submission-PBJ.html
QTSO.com –
https://www.qtso.com/vendorpbj.html
Email - PBJ Technical Question
NursingHomePBJTechIssues@cms.hhs.gov. Email - PBJ policy Questions
nhstaffing@cms.hhs.gov
Listserv
https://www.qtso.com/vendor/post.php 

Report of one of the first Dementia focused surveys: From Texas Medicaid Coalition Call

This was sent to me from a colleague who participated in the Texas Medicaid Coalition (TMC) call last week.  An Administrator describes the Dementia focused survey.  I have removed any reference to the facility or the administrator, but  he or she freely described the survey during the call with all Texas providers on the TMC.

A facility in Dallas had the first Texas Dementia Focused Survey this week. During my monthly TMC conference call today, [redacted' Administrator, shared [his or her] experience. The building has a census of 86 – 20 have dementia. Administrator said this was explained to him/her as a full book survey of only dementia patients. The final count was at least 7 tags. Administrator stated that 50% of the survey was directed at Activities, 35% directed at Social Services and the rest was nursing.

10 surveyors entered the building at 8 am on Monday morning. 5 were from CMS (federal) and 5 were from DADS. {Texas survey agency] Of the 10, 6 were there for observation/training only. They arrived at 8 am and left at 7 pm the first day. They arrived at 8 am the second day and exited at 3 pm. 

On entry, they requested:

• a list of all dementia patients with their diagnosis
• 802/672
• bath times
• meal times
• care plans
• ADL plan of care (did the CNAs know which residents had dementia? Heavy focus on whether residents were having BM's)
• med pass times
• P & P as it relates to dementia residents
• Social Worker files
• Activity Director files and activity calendars
• Surveyors requested the facility set up a care plan meeting with at least one resident identified as having dementia – They wanted the medical director or resident's MD, psychologist, psychiatrist, pharmacy consultant, family, housekeeping, dietary, maintenance, nurse aides,,,, as many as possible in attendance
• Proof of Dementia training for staff
• Requested QA sign in page to see who attends the meetings

While they were there, they:

• Watched baths, med pass, and the dining room. Do they resist care while bathing - how do the CNAs handle it?  Do they go to the dining room to eat? Do the CNAs communicate with the resident in the dining room – do they tell them why they are in the dining room. One of the CNAs did not explain to the resident why they were being taken to the dining room and they were cited.
• Reviewed psych consents and behavior monitoring sheets – an issue was not all (both psych consents and behavior monitoring sheets) had the exact behaviors that were monitored, forms not completely filled out.  They wanted to know if we knew the resident's behaviors.
• Reviewed proof that someone (not just the Pharm consultant) is tracking the antipsychotics and there is a process for identifying opportunities for reduction. They wanted to see tracking and trending
• Based on their census of 20, were there enough staff (nurses and activity staff) to provide care?
• Reviewed the Social Services behavior assessments
• Reviewed weight loss
• Heavy focus on In-room activities – are the in-room activities specifically mentioned in the care plan? They had a room with 3 females with dementia and the Activity Director was playing music in the room. The surveyor asked what was going on – The AD stated she was doing in-room activities. The AD was asked if it was care planned for the three residents and because it was only care planned for two of them, they were cited.
• Activities not performed as scheduled. One program was not provided and they were cited.
• Home like environment – in one room there were no pictures on the wall. Also, the resident's room mate had just been sent to the hospital. The room-mate was on an alternating pressure mattress and the DMI company had picked it up. No pictures and no mattress on the bed equalled lack of home like environment.  They were cited.
• Watched peri-care – one resident mentioned pain while the CNA was doing peri-care and the CNA did not immediately notify the nurse. Another resident had been in bed for 3 hours and the CNA provided peri-care before getting the resident ready for meal time. When the CNA got the resident up she forgot to put a cushion in the wheelchair. They were cited under Quality of Care-pressure ulcers and provision of services.
• Reviewed every MDS and closely monitored if the diagnosis in the chart (within the last 60 days) matched the diagnosis on the MDS
• They interviewed the Administrator and the DON – Adm described it as intense and in-depth. 
• Four surveyors interview the Administrator. 
  They wanted to know how you developed your policies and procedures. What type of guidelines do you use.? The ADM said they strongly favored the Alzheimers as being the guidelines used. How do you know your dementia residents are being cared for adequately. 
• Ten surveyors interviewed the DON.  They asked specifically about each of the 20 patients regarding the care provided, pressure ulcers, peri care ADL's, meds, how do the CNAs communicate with the residents, etc.

Tags:

Activities – F-248 – not providing activities as stated - one program not performed as stated on calendar

Homelike environment F252 

Dignity  F-241 Dining Room incident

Unnecessary Drugs F-329

Performance of Services

SW not actively pursing guardianship – F-250

Quality of Care – pressure ulcers F314

Care Plans F-280

15 facilities in Texas have already been pre-chosen for the Dementia Focused Surveys. 

Virginia Medicaid Hospice Reimbursement to Become RUGs-Based July 1, 2015

From the Virginia Health Care Association

When Virginia Medicaid switched to RUGs-based billing for nursing facility care last November, the Department of Medical Assistance Services (DMAS) did not make the switch for Hospice providers based on both DMAS’ and the providers’ readiness for the change.  As you know, when a nursing facility resident enters hospice, the hospice provider is paid by Medicaid at 95 percent of the nursing facility rate; the hospice provider then pays the nursing facility based on the contract between the facility and the hospice provider.

The switch to RUGs-based billing essentially created 34 rates per facility as opposed to one facility-wide rate; neither DMAS nor the hospice providers had made the system/procedure changes necessary to implement the change.  As a result, DMAS defaulted to the July 1, 2014 facility case mix adjusted rate as its basis for hospice reimbursement, as opposed to the November 1 rates, and the hospices followed suit in their payment to nursing facilities.  In the interim, DMAS has been working with the hospice providers, with input from the nursing facilities, on the change to RUGs-based hospice reimbursement, to be effective July 1, 2015.  To that end, DMAS released a memo dated May 18, 2015 outlining the change.

From a nursing facility perspective, you may need to revisit your contract(s) with hospice providers to ensure the language accommodates the reimbursement change.  Additionally, under the methodology change, the hospice providers will need to know the appropriate RUGs assignment (to determine the rate) for both their billing to DMAS and their payment back to the nursing facility.  As such, you will likely need to include the RUGs information (in whatever form the parties agree) on communication to the hospice to ensure accurate and timely billing and payment.

Virginia DMAS seeking public comment on their plan to move everyone to mandatory dual-eligible managed care

Good Afternoon,

The Department of Medical Assistance Services (DMAS) appreciates your support and cooperation with the significant reforms that the department has undertaken in the past few years. Our work isn’t finished and we continue to look to each of you, as our trusted stakeholders and partners, as we continue to design, develop, and implement initiatives and programs to better serve the citizens of the Commonwealth.

I am proud of all DMAS has accomplished in the past few years, and want to share with you the next iteration of program and policy enhancements. While this email is lengthy, it is important that I share as much detail as possible as these enhancements will have a far reaching impact across the Medicaid stakeholder community.

Over the next couple of years, DMAS will move the majority of the remaining Medicaid fee-for-service populations into coordinated and integrated managed care models. These populations include individuals with full Medicaid and Medicare benefits, called dual eligibles, who are not enrolled in the Commonwealth Coordinated Care Program (CCC); and individuals who receive full Medicaid and long-term services and supports (LTSS) either through an institution or through one of DMAS’ six (6) home and community based services (HCBS) waivers. Please note, at this time the expansion of Medicaid managed care for individuals enrolled in the Day Support for Persons with Intellectual Disabilities (DS); Intellectual Disabilities (ID); and, Individual and Family Developmental Disabilities Support (DD) Waivers is being considered for their acute and primary care services, only.  

While DMAS is exploring the feasibility of managed or integrated care models for the ID, DD, and DS Waivers, these individuals will continue to receive their home and community-based LTSS through Medicaid fee-for-service until the Department of Behavioral Health and Developmental Services (DBHDS) completes the redesign of these Waivers. 

DMAS has been directed by the Virginia General Assembly to transition  these populations into managed care so the Commonwealth can take advantage of the benefits of managed care as a delivery model, including: (1) increased access due to larger and more comprehensive provider networks and network management; (2) accountability; (3) administrative benefits DMAS has not been able to replicate (care management, nurse and other call lines, maternity and education programs); (4) budget predictability through capitated payments; (5) focused quality improvement programs; and, (6) tighter and more complex medical management. 

Many of you played, and continue to play, a significant role in helping DMAS develop the Commonwealth Coordinated Care (CCC) program which was implemented in March 2014, and integrates medical, behavioral health, and LTSS while combining Medicaid and Medicare funding. Approximately 66,000 full-benefit duals are eligible for the CCC program, though only 27,000 have chosen to enroll in the program.  While DMAS continues to work in the CCC demonstration regions to improve provider and individual participation, DMAS needs to take additional steps to transition these individuals into managed care.

DMAS is developing initiatives (as described in the table below) to transition the remaining FFS populations and services into managed care. These initiatives will permit an additional 107,000 individuals to benefit from managed care. 

Transitioning Remaining Medicaid FFS Populations into Mandatory Managed Care
Proposed Phase I: Enroll Individuals Who Are Eligible for the CCC Program but Choose Not to Participate in CCC Into Mandatory Managed Care Timeframe: Summer 2016	Proposed Phase II: Enroll Remaining Duals and LTSS Populations into a Mandatory Managed Care Program Timeframe: Mid 2017
·   Transition approximately 37,000 CCC eligible individuals who have chosen not to participate in CCC into a mandatory managed care program for Medicaid services. ·   Includes primary and acute, LTSS, and behavioral services coordinated by a CCC health plan (Anthem, Humana and Virginia Premier).  ·   Provides care coordination with the goal of improving health outcomes.  ·   Individuals will continue to have the option to enroll in CCC. ·   This program will be phased-in regionally.	·     Develop and implement a new managed care program for the remaining LTC populations and services. ·     Includes primary and acute, LTSS, and behavioral services. The health plans will be selected through a competitive procurement process. ·     There are two general populations to transition into a new Medicaid managed care program coordinated by a health plan. ·     Approximately 50,000 dual eligibles that are currently not in the CCC demonstration regions or are currently excluded from CCC (such as children and individuals in select home and community based waivers). Approximately 20,000 non-dual eligibles who receive LTSS either in an institution or through one of DMAS’ six home and community based care waivers.  At this time the expansion of Medicaid managed care for individuals enrolled in the DS, ID, and, DD Waivers is being considered for their acute and primary care services, only. While DMAS is exploring the feasibility of managed care models for the ID, DD, and DS Waivers, these individuals will continue to receive their HCBS through Medicaid fee-for-service until DBHDS completes the redesign of these waivers. ·     This program will be phased-in regionally.

You will continue to receive additional details on these initiatives to keep you fully informed and engaged. We are also seeking public comment about the proposed design and implementation for these initiatives. (The Opportunity for Public Comment notice is attached). In addition, any developing information and future public comment documents will be posted on the DMAS homepage under, “What’s New.” As stakeholders, DMAS also need your help in assuring that accurate information about these initiatives is shared especially to dispel inaccurate perceptions that come to your attention.  Thank you for your dedication and continued service on behalf of all individuals who benefit from Virginia’s Medicaid programs.  DMAS looks forward to working together! 

Tammy Driscoll

Senior Programs Advisor to the Deputy of Complex Care and Services

Virginia Department of Medical Assistance Services (DMAS)

600 East Broad Street

Richmond, VA 23219

804-225-2552

Tammy.Driscoll@DMAS.Virginia.Gov 

Managed Long Term Services and Supports (MLTSS)

Opportunity for Public Comment

Purpose of Request: This is an opportunity to provide public comment on the proposed design and implementation of DMAS’ program initiative to transition remaining fee-for-service populations into a mandatory managed care program.  This is not a formal solicitation and the Department of Medical Assistance Services (DMAS) will not award a contract based on submitted responses.  This is strictly a means for DMAS to obtain initial stakeholder input in the design of a Managed Long Term Services and Supports (MLTSS) program.  

Important Date: If you or your organization plans to submit public comments, please send your comments to VAMLTSS@dmas.virginia.gov by 5:00 p.m. on June 1, 2015.  There will be additional opportunities for public comment. The Department will also continue its longstanding practice of meeting regularly with stakeholder groups, providing information and gathering additional input on the important features of an MLTSS program.

Length of Responses: Responses should be typed, page-numbered, and should be no more than a total of 5 single-spaced pages in length using 12-point Arial font. 

Legislative Directive: The 2013 Virginia Acts of Assembly directed DMAS to implement three phases of Medicaid reform. The third phase is “to include all remaining Medicaid populations and services, including long-term care and home- and community-based waiver services into cost-effective, managed and coordinated delivery systems.” (Item 307.RRRR.4. -  http://lis.virginia.gov/131/bud/hb1500chap.pdf). The 2015 Virginia Acts of Assembly, (Item 301.TTT) again directed DMAS to expand principles of care management to all geographic areas, populations, and services under programs administered by the Department.

This Opportunity for Public Comment will help DMAS meet both of these directives. 

Virginia’s Experience with Coordinated Care: Virginia has extensive experience with implementing managed and coordinated care programs.  To date, approximately 74 percent of all Virginia Medicaid beneficiaries are enrolled in some form of managed or coordinated care.  Specifically,

·       Virginia began operating managed care in 1996 in the Tidewater region.  Now named Medallion 3.0, the program serves over 700,000 individuals statewide, including low-income children and families and non-dual eligible individuals who are seniors or who have disabilities. 

·       DMAS operates a full-risk managed care program for individuals over the age of 55 who receive Medicare and Medicaid benefits–the Program for All Inclusive Care for the Elderly (PACE).  The PACE program provides all Medicare and Medicaid benefits under one entity anchored by an adult day health center.  There are thirteen (13) PACE sites located throughout the Commonwealth, serving just over 1,300 individuals. 

·       In April 2014, DMAS implemented the Commonwealth Coordinated Care (CCC) Program- a demonstration in partnership with the Centers for Medicare & Medicaid Services (CMS) that serves individuals receiving Medicare and Medicaid (dual eligibles) under a capitated full-risk managed care model.  Approximately 27,000 individuals are served in this program in select regions in Virginia.   

·       Most recently, in December 2014, DMAS transitioned non-dual eligible Elderly or Disabled with Consumer Direction (EDCD) Waiver individuals into Medallion 3.0 for their acute and primary care services.  Referred to as the Health and Acute Care Program (HAP), these individuals receive their waiver services through Medicaid fee-for-service (FFS) as “carved out” services.  Almost 8,000 individuals participate in this program.    

Virginia’s Current HCBS Program: Most of the individuals who continue to receive services through the Medicaid FFS system are dual eligibles (except for those participating in PACE or CCC) and individuals receiving long-term services and supports (LTSS), either through an institution or through one of DMAS’ six (6) home and community-based services (HCBS) waivers: (i) Alzheimer’s Assisted Living; (ii) Technology Assisted; (iii) Elderly or Disabled with Consumer Direction; (iv) Day Support for Persons with Intellectual Disabilities (DS); (v) Intellectual Disabilities (ID); and, (vi) Individual and Family Developmental Disabilities Support (DD). 

Virginia’s Upcoming Proposed Plans for MLTSS: Building on DMAS’ managed and coordinated care experiences, DMAS plans to implement an MLTSS program to provide individuals with a more integrated and seamless delivery system starting in 2016. 

Please note, at this time MLTSS for individuals enrolled in the DS, ID, and, DD Waivers is being considered for their acute and primary care services, only.  While DMAS is exploring the feasibility of managed/coordinated care models for the ID, DD, and DS Waivers, these individuals will continue to receive their home and community-based LTSS through Medicaid fee-for-service until the Department of Behavioral Health and Developmental Services completes the redesign of these Waivers. 

Nationally, the number of MLTSS programs has increased significantly over the past decade and is expected to increase even more as the number of seniors expands.  MLTSS programs represent arrangements between state Medicaid programs and managed care plans or other contracted entities. These entities receive combined payments to fully integrate an individual’s primary, acute, behavioral health and HCBS and/or institutional services. 

MLTSS programs provide an opportunity to create a seamless, integrated health services delivery program. Some of the goals of MLTSS include:

·       Improved quality of life, satisfaction, and health outcomes for individuals who are enrolled;

·       A seamless, one-stop system of services and supports;

·       Service coordination that provides assistance  in navigating the service environment, assuring timely and effective transfer of information, and tracking referrals and transitions to identify and overcome barriers;

·       Care coordination for individuals with complex needs that integrates the medical and social models of care, ensures individual choice and rights, and includes individuals and family members in decision making using a person-centered model; 

·       Support for seamless transitions between service/treatment settings;

·       Facilitation of communication between providers to improve the quality and cost effectiveness of care;

·       Arranging services and supports to maximize opportunities for community living; and,

·       System-wide quality improvement and monitoring.

Opportunity for Public Comment: As DMAS moves forward with developing an MLTSS program, significant and ongoing stakeholder input will be necessary to ensure that this initiative effectively meets the needs of individuals and providers. 

Questions for Public Comment

(As a valued stakeholder you are invited to respond to any or all of the questions below.)

General:

1.     What would you like to see as the top three significant features of an MLTSS program?

2.     What suggestions do you have as DMAS continues to explore the feasibility of including acute and primary care in the MLTSS program for individuals enrolled in the ID, DD, and DS Waivers? 

Beneficiary Experience:

3.     What protections do you consider to be essential for individuals in an MLTSS program (e.g., enrollment/disenrollment services, including choice counseling; offering consumer direction; continuity of care provisions so individuals can maintain relationships with current providers; an advocate or ombudsman to help individuals understand their rights, responsibilities, and how to handle disputes with the managed care system or state; a critical incident management system)? 

4.     What considerations should be kept in mind when developing person-centered needs assessments, service planning, and care coordination requirements to meet the individual’s medical and non-medical needs?

5.     What would you consider to be the most significant features in assisting individuals to transition between providers and service/treatment settings?

6.     What would make an MLTSS program attractive to individuals? 

Provider Experience:

7.     What program features do you see as important to providers who are making the transition to an MLTSS program (e.g., a payment floor, ease of authorization, billing, and payment processes)?

8.     What would make an MLTSS program attractive to providers?

Service Package:

9.     What are your recommendations for the design of a comprehensive and integrated supports and service package?  For example, would you recommend community-based  behavioral health services be included in the benefit package or be managed by a behavioral health services administrator?  

10.  What thoughts do you have on how DMAS should handle Fiscal/Employer Agent (F/EA) services for Waiver individuals who choose consumer direction of eligible waiver services?  Should DMAS require that the health plans contract with the Department’s designated F/EA or should DMAS give the health plans flexibility in determining how they want to provide or which entity they want to subcontract with to provide the F/EA services?

Health Plans:

11.  What are your recommendations for health plan requirements (e.g., accreditation, offer a Medicare Advantage Plan with Prescription Drug Plan or a Medicare Special Needs Plan, experience providing services to special needs populations, other core competences)?

12.  What strategies would you recommend the health plans utilize to maximize coordination with Medicare for individuals who are dually eligible?

13.  What value-based payment opportunities would you suggest the health plans implement to reward providers for implementing health care transformation that could result in better clinical outcomes, improved member satisfaction, and cost containment under an MLTSS program?

Quality Measures:

14.  Quality measures will help maintain accountability and transparency. In what areas of the program will it be most important for you to measure quality?

Financing:

15.  Provide recommendations regarding financing, incentives, and other value based strategies to demonstrate high-quality, person-centered and cost-effective supports and services to individuals who are eligible for MLTSS.

Outreach and Communication:

16.  What would be the most effective strategies for engaging individuals and providers in outreach and education efforts regarding a new MLTSS program?

17.  What would be the most important messages individuals and providers would need to hear as they begin planning for transitioning to an MLTSS program?

MDS Focused Survey Tools Now Available

The MDS Focus Worksheet that CMS requires to be completed within one hour is now in the "Resources" section of my website.  You will find the CMS word document and also an Excel spreadsheet version of the worksheet you can maintain electronically.  Also there is an Entrance Conference Worksheet used in the very early 2015 MDS/Staffing Focused Surveys in March of 2015.  I also still have the pilot tools used as well.   

From AHIMA: HR 2247 would not delay ICD 10, but implement an 18 month grace period

From AHIMA:  This bill would not delay ICD 10.  We all need to be moving toward Oct 1 implementation:

New House Bill Calls for ICD-10 Transition Period, But Not a Delay

Posted By Chris Dimick on May 13, 2015

A new bill has been introduced into the US House of Representatives that calls for a required ICD-10 transition period following the code set’s implementation on October 1. The bill, H.R. 2247, the Increasing Clarity for Doctors by Transitioning Effectively Now Act (ICD-TEN Act), would “require the Secretary of Health and Human Services (HHS) to provide for transparent testing to assess the transition under the Medicare fee-for-service claims processing system from the ICD-9 to the ICD-10 standard, and for other purposes.”

The bill, introduced on May 12 by Rep. Diane Black (R-TN-6), would not halt or delay the October 1, 2015 implementation deadline for using ICD-10-CM/PCS, nor would it require the Centers for Medicare and Medicaid Services (CMS) to accept dual coding—claims coded in either ICD-9 or ICD-10. However, the bill would require HHS to conduct “comprehensive, end-to-end testing” available to all providers to assess whether the Medicare fee-for-service claims processing system is fully functioning with the new ICD-10 code set.

This transition testing period would last 18 months, at which point HHS would be required to submit a report to Congress certifying whether or not the ICD-10 standard is fully functional and not hindering the fulfillment of provider claims. HHS would need to prove that it is processing and approving at least as many claims as it did in the previous year using ICD-9. If the transition is not deemed “functional” based on this benchmark, HHS would need to identify additional steps that it would take to ensure ICD-10 is fully operational in the near future, according to the bill.

During the transition period and any ensuing extensions, no reimbursement claim submitted to CMS could be denied due solely to the “use of an unspecified or inaccurate subcode,” according to the bill.

“In the past, Congress has repeatedly delayed the switch from the ICD-9 coding system to the far more complex ICD-10 system out of concern about the effect on providers. Neither Congress nor the provider community support kicking the can down the road and supporting another delay, but we must ensure the transition does not unfairly cause burdens and risks to our providers, especially those serving Medicare patients,” Black wrote in a letter urging fellow legislators to cosponsor the ICD-TEN Act. “During the ICD-10 transitional period, it is essential for CMS to ensure a fully functioning payment system and institute safeguards that prevent physicians and hospitals from being unfairly penalized due to coding errors.”

AHIMA officials have stated they are not in favor of this bill since ICD-10 contingency plans already supported by CMS have been put in place, are working well, and will ensure the industry is ready to effectively use ICD-10 in October.

For example, CMS has already begun conducting end to end testing with providers, the results of which have been positive and on par with ICD-9 claims. Results from the first week of CMS testing that ran January 26, 2015 to February 3, 2015 showed that 81 percent of test claims submitted by providers in ICD-10 were accepted, according to CMS.

This shows the healthcare industry will be ready for ICD-10 on October 1, 2015, and that a transition period is not necessary, said Margarita Valdez, senior director of congressional relations at AHIMA.

Also, CMS has indicated that it could grant “advance payments” to any physicians that do experience cash flow disruptions as a result of the ICD-10 transition. CMS already has existing payment policies that it uses when a provider has incurred a temporary delay in its billing process causing financial difficulties for a provider, which could be used to help providers after the ICD-10 transition, Valdez said.

However, the proposed 18-month grace period on coding, where nearly all claims would be accepted, and is called for in H.R. 2247, would “create an environment that’s ripe for fraud and abuse,” Valdez said.

In summary, the bill would:

• Still require the use of only ICD-10-CM/PCS beginning October 1, 2015
• Require CMS to conduct full end-to-end testing and to certify to Congress that the Medicare fee-for-service claims processing system is fully functioning using ICD-10
• Implement an 18-month “safe harbor” transitional period after the October 1, 2015 implementation date to protect providers should they make a “minor” mistake using the wrong ICD-10 sub-code
• Prevent the rejection of claims and denial of payment based solely on sub-coding specificity during the implementation phase

The bill was referred to the Committee on Energy and Commerce and the Committee on Ways and Means. Black serves on the Ways and Means Committee. The bill currently has one cosponsor, Rep. Andy Harris (R-MD-1).