In a letter this week to the Centers for Medicare & Medicaid Services, more than 100 medical societies aired "a number of concerns that do not appear to be addressed" as the ICD-10 deadline looms.

[See also: CMS touts end-to-end ICD-10 test success]

Writing March 4 to CMS Acting Administrator Andrew Slavitt, the groups – including American Medical Association, the American Academy of Family Physicians and most state medical associations – made the case that "the transition to ICD-10 represents one of the largest technical, operational, and business implementations in the health care industry in the past several decades."

As they gird for the "profound impact" the code set change will have on physicians, the medical groups pointed to several areas they find lacking less than seven months from the Oct. 1, 2015, transition deadline.

[See also: ICD-10 cost a 'crushing burden' for docs]

Chief among them is testing. Despite CMS' triumphant announcement this past week that it is "ready for ICD-10" – touting a success rate of 81 percent claims accepted in end-to-end testing with volunteer providers, clearinghouses and billing agencies, the letter writers argue that "there still remains a lack of industry-wide, thorough end-to-end testing of ICD-10 in administrative transactions."

The data from those end-to-end tests "show only a broad overview of the number of claims received (14,929), number of claims accepted (12,149), acceptance rate (81 percent), and partial information about the reasons and percentages of rejected claims," they write. That acceptance rate "was still well below average, and we continue to be concerned about the limited scale of testing being performed."

Beyond the matter of claims processing, the physicians expressed deep concerns about the "ability to correctly collect and calculate quality data during and after the transition to ICD-10." While CMS has specified quality measures for ICD-10, "we foresee unintended consequences for measure denominators and measure rates due to potentially conflicting timelines," they argue.

For example, while ICD-10 is expected to begin in earnest on Oct.1, 2015,  the Physician Quality Reporting System and meaningful use quality reporting periods are based on the calendar year, according to the letter. As such, "many of the MU and PQRS measures capture encounters pre and post visit and will straddle the October 1 date, requiring that physicians report ICD-9 for the first segment and ICD-10 for the final portion."

So far, at least, CMS hasn't indicated "how it plans to address and correctly tabulate quality performance reporting metrics after the transition to ICD-10."

The stakeholders also cite concerns about risk mitigation – for instance pointing out that "previous HIPAA mandates – such as the National Provider Identifier, NPI, and the upgrade to Version 5010 transactions – resulted in significant claims processing disruptions that caused physicians to go unpaid for weeks and sometimes months." Those were much less complex than ICD-10, but "still resulted in significant disruptions."

Meaningful use certification is another worry: Docs who bill Medicare must use a certified electronic health record or face MU penalties – Version 2014 certified software is required to accommodate ICD-10 codes, the letter points out – but "many EHR vendors were behind in delivering upgrades to physicians in 2014 to meet the MU program. There is no data that indicates when vendors will be ready to deliver the ICD-10 upgrades and what help will be available for physicians whose vendors decided not to certify to 2014."

As physicians asked to "assume this significant change at the same time they are being required to adopt new technology, re-engineer workflow and reform the way they deliver care," the signatories wrote that they "remain gravely concerned that many aspects of this undertaking have not been fully assessed and that contingency plans may be inadequate if serious disruptions occur on or after October 1."