Following up on the CMS’s administrator’s ICD-10 or bust comments at the HIMSS conference last week, the American Medical Association is begging CMS for an ICD-10 contingency plan. Medical Economics reports that 

The American Medical Association (AMA) says it’s “deeply concerned” that a contingency plan has not been put in place if issues occur during ICD-10 testing this month. “The slightest glitch in the ICD-10 rollout could potentially cause a billion dollar back-log of medical claims that jeopardizes physician practices and disrupts patients’ access to care,” Ardis Dee Hoven, MD, president of the AMA, said in a written statement. “The AMA is deeply concerned that Medicare does not have a back-up plan if last minute testing demonstrates anticipated problems with this massive coding transition. At the end of the day sticking hard and fast to the ICD-10 deadline without a back-up plan to address disruptions in medical claims processing will hurt doctors and their patients.”

Understood and agreed.
The Affordable Care Act regulators issued a veritable flood of regulations late on Wednesday afternoon. HHS issued the 335 page long final 2015 benefit and payment parameters notice. This behemoth prescribes the 2015 out-of-pocket maximum for group health plans, including FEHB plans — $6,600 for self-only coverage and $13,200 for other than self-only coverage and it expands on the rules for the transitional reinsurance fee. That fee will generate $25 billion from health plans over three years (2014-2016) to fund a transitional reinsurance fee for the qualified health plans in the exchanges and to reimburse the U.S. Treasury $5 billion dollars for the ACA’s Early Retiree Reinsurance Fund.  While HHS barred FEHB plans from participating in this program, it is happy to accept this reimbursement from them. Benefit cost curve up. 
IRS issued rules implementing the IRC Section 6055 and 6056 reporting requirements. Both of these requirements take effect next year (following a one year administrative delay) and pose herculean tasks for health plans. The 6056 requirement is imposed on employers to support compliance with the ACA’s employer shared responsibility mandate, and the 6055 reporting requirement is imposed on health plans outside the exchanges, including FEHB plans, to support compliance with the ACA’s individual shared responsibility mandate. In order to meet the 6055 reporting requirement health plans will have to solicit Social Security Numbers for all plan members. Plans typically have employee Social Security Numbers but not dependents.  Administrative cost curve up.
In an effort to reduce administrative costs, CAQH, which is a coalition of health plans and providers, has created a coordination of benefits databank known as COB Smart which just launched last month. 

COB Smart is being rolled out on a market-by-market basis. The solution is currently live in 15 states; the remainder of the country is scheduled to go live later in 2014. The impact of this solution will amplify throughout the U.S. as more organizations adopt COB Smart.
“COB Smart is addressing the frustrations that patients, providers, and health plans sometimes experience with benefit coordination,” said Robin Thomashauer, Executive Director of CAQH. “Efficient COB processes are integral to ensuring providers receive the right payment and health plans process the correct claims the first time.”
CAQH and its member health plans worked together to design COB Smart. Participating health plans include Aetna; AultCare; Blue Cross and Blue Shield of North Carolina; BlueCross BlueShield of Tennessee; CareFirst BlueCross BlueShield; Cigna; Health Net, Inc.; Horizon Healthcare Services, Inc.; Kaiser Permanente; UnitedHealthcare; and WellPoint, Inc., on behalf of its affiliated health plans. Each of these health plans has committed to adopt the solution.