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With Oct. 1 fast approaching and many providers getting more anxious about the ability of the claims processing systems to function properly, the Centers for Medicare & Medicaid Services (CMS) recently tried to alleviate some of that anxiety – but instead, they added to it.

First, on Sept. 9, CMS released a notice of a new MLN Matters, SE 1522, titled “Claims Submission Alternatives for Providers Who Have Difficulties Submitting ICD-10 Claims.” That title seemed to offer great potential, suggesting that CMS anticipated claim submission issues and had developed alternative methods for providers. Unfortunately, clicking on the provided link revealed the details of the document, but no link to the document itself.

Likewise, a search of the “2015 transmittal” section of the CMS website revealed a link to the document, but once again no actual document. It was not until Sept. 16, a full week later, that the actual MLN Matters was posted.   

The MLN Matters indicates that it “offers physicians, providers, and suppliers information that will assist them in avoiding claims processing disruptions after implementation of International Classification of Diseases, Tenth Edition (ICD-10) on October 1, 2015.” It also purports to “(provide) information for providers who have difficulties submitting ICD-10 claims due to being unable to complete necessary systems changes or having issues with billing software, vendor(s), or clearinghouse(s).” But as encouraging as this introduction sounds, provider anxiety did not end there.

The first section is titled “free billing software for providers that submit claims to MACs (Medicare Administrative Contractors).” “Free” always sounds good, but as the saying goes, nothing is ever really free. And in this case, reading further indicates that while the software is free, “there may be fees associated with submitting claims.” The document then refers readers to a listing of contractors’ ICD-10 claims submission alternatives Web pages. Here one can find a list of every Medicare part A, B and DME MAC, with a link to their submission alternative pages. Now we’re getting somewhere.

But once again, frustration is lingering. On the top of the list is Noridian Healthcare Solutions, Jurisdiction E, Part A. Clicking that link takes one to a Web page indicating that “the proxy server received an invalid response from an upstream server.” The same error occurs with all 4 Noridian links. Novitas Solutions, Jurisdiction H is next. This link works and takes one to their site, where users have to click on another link to download the actual software. This page provides step-by-step instructions, with the first step being a technical check and the second being enrollment for PRO-ACE Pro32. Three are two enrollment choices: dial-up (does that even exist in 2015?) and enrollment through the Novitasphere Internet Portal. But choosing that option results in another dead end, with an error message reading “Novitasphere Portal is not available for Part A providers at this time. Check back in the future for updates.”

NGS, which has several jurisdictions, has a functioning website, but once again a user must go to the PRO-ACE Pro32 install instructions page, where the PC-ACE Pro32 Enrollment – EDI Submitter Action Request Form that must be completed if a provider wants to submit claims electronically can be found. Clicking that link results in a “404 NOT FOUND” error and yet another dead end.

Of course, the MLN Matters also notes that in limited situations, you may submit paper claims with ICD-10 codes to Medicare. But that section indicates that to be eligible to submit paper claims, a provider must apply to the MAC for a waiver of the Administrative Simplification Compliance Act, a process that, as stated on the NGS Claims Submission Alternatives page, should be completed by Aug.  17, 2015 to ensure a response by Oct. 1, 2015.

With less than two weeks until Oct. 1, a MLN Matters that should have provided useful information and possible alternatives for providers only added to their anxiety, in some cases.

It’s a shame that CMS and the MACs did not take the time to ensure their processes were in place to provide viable alternatives.

About the Author

Ronald Hirsch, MD, FACP, CHCQM is vice president of the Regulations and Education Group at Accretive Physician Advisory Services at Accretive Health. Dr. Hirsch’s career in medicine includes many clinical leadership roles at healthcare organizations ranging from acute care hospitals and home health agencies to long-term care facilities and group medical practices. In addition to serving as a medical director of case management and medical necessity reviewer throughout his career, Dr. Hirsch has delivered numerous peer lectures on case management best practices and is a published author on the topic. He is a member of the American Case Management Association and a Fellow of the American College of Physicians.

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