Sometimes it’s fun to critique my health IT editor colleagues in this space, but this time, I can do nothing but agree with a column written by FierceHealthIT editor Dan Bowman.

In his column, he notes that physician practices and hospitals have been quite worried about the transition from ICD-9 to ICD-10, something which is inevitable given the complexity of the switchover. And with the switch set to go into effect Oct. 1, 2014, the time available to prepare is flying by.

So, he says, it’s definitely a Good Thing that CMS may be amenable to do external ICD-10 testing, despite previously asserting that it wouldn’t do so. Now, bear in mind that CMS hasn’t promised to do external testing — it’s just said that it would consider the idea — but that’s encouraging news.

After the mind-blowing failure of, CMS hardly needs another disastrous failure of systems or operations in one of its key responsibility areas. What’s more, if ICD-10 coding doesn’t work right, we’re talking about tying up millions (or even billions) of dollars in reimbursement to providers. That could prove to be a disaster which makes the debacle look like a minor blip.

Given that a failure of testing was instrumental in the debacle, I can’t imagine why CMS wouldn’t have become super-cautious in its wake. The last thing CMS needs is mass confusion, delayed payments, undercoding, upcoding, fraud….need I go on?

As things stand, CMS’s IT operation is already in turmoil, with the agency’s CIO having resigned and other heads still likely to roll. And Congress, for once understandably, isn’t going to have a lot of patience with anything resembling another IT failure.

CMS, don’t tell the public you don’t have the resources to do more extensive ICD-10 testing. Find them. Your future as an agency may depend on it.

Meanwhile, readers, if you want to keep up with ICD-10 twists and turns, don’t miss John Lynn’s ICD-10 Tuesdays. He’ll have plenty of insights to offer as the big day approaches.

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