The Affordable Care Act (ACA) requires new standards, operating rules, and identifiers in the upcoming years.  ACA also requires health plans to certify compliance with standards and operating rules and that they have completed end-to-end testing.

Since all services provided on or after October 1, 2014 will require ICD-10 coding, testing is a necessary step in your implementation of the ICD-10 code set to ensure your software system sends and receives diagnoses correctly.  Therefore, testing is essential to ensure compliance with the requirements ensuring the ICD-10 codes are sent from your system to the receiving system correctly, and then processed appropriately to avoid interruption of transaction flow.

2 types of testing:

  1. Internal Testing– done within your organization to identify if the programming/software changes for ICD-10 code set are correct and functioning correctly.  You will want to talk to your software vendor to see if they will help you with internal testing
  2. External Testing– this is the sending and receiving transactions that include ICD-10 with your business associates and trading partners through systems that you are currently using.

You should give yourself plenty of time for internal and external testing.  American Medical Association recommends allowing 2-3 months for internal testing and 6-9 months for external testing.

CMS awarded National Government Services (NGS) with a one-year contract to develop a process for End-to-End testing with all Administrative Simplification Requirements.  This more efficient and less time consuming testing process will be a best practice industry wide for health care provider testing of future standards. ICD-10 will be the first pilot test case.

CMS end-to-end testing


Gina Tomcsik

Director of Compliance

Functional Pathways