GAO expresses doubt in HCFA’s Y2K readiness

Not all internal systems will test before next year

In another chapter of "Yes, it’s ready. No, it’s not," the Government Accounting Office (GAO) in Washington, DC, recently reported that the Health Care Financing Administration (HCFA) in Baltimore has overstated its readiness to handle year 2000 (Y2K) computer problems.

The testimony was delivered to the House of Representatives Ways and Means Committee on Feb. 24. As recounted by the Medical Group Management Association (MGMA) in Englewood, CO, the GAO is concerned that HCFA’s failure could delay both Medicare and Medicaid reimbursement payments to providers and the implementation of the year 2000 scheduled fee updates. In addition, HCFA may experience problems processing provider claims in the first quarter of 2000.

Here are details of the GAO’s concerns:

  • Incomplete independent testing of internal systems. HCFA has indicated to Congress that all of their 54 mission-critical systems were now Y2K-compliant, with the exception of a few "minor problems." Conversely, the GAO contends that none of the 54 mission-critical systems are truly compliant.

    The independent testing contractor, hired by the government to verify Y2K compliance, has concluded that it will only be able to test eight internal systems, down from the 22 that HCFA previously stated would be independently tested. This independent testing will not be completed until late summer, which is very late to implement system changes or develop contingency plans.

    In addition, the GAO reports that HCFA has not established an integrated schedule to track all of the agency’s major internal systems or a formal risk management system. The GAO is concerned that without this integrated schedule, HCFA’s management team will not be able to properly identify important system dependencies and prioritize the remaining work in the limited time before 2000.

  • Noncompliant data exchange systems. The GAO testimony, as reported by MGMA, indicates that of HCFA’s 3,418 internal data exchange systems, 309 are not Y2K-compliant, and of 255,000 external data exchange systems, more than 37,000 are not compliant. In addition, HCFA has several internal systems scheduled for a software upgrade in 1999 — several that are legislatively mandated. All of these upgraded systems will require testing and certification.

  • No definite plan for "end-to-end" testing. In addition to testing individual systems, HCFA must also perform what is termed "end-to-end" testing, which involves testing interrelated systems that collectively support an organizational business function. The GAO is concerned that HCFA has yet to develop a comprehensive plan that fully discloses how these tests will be completed and a specific schedule for conducting them.

  • No appropriate contingency plans. The GAO also is concerned that HCFA has not constructed an appropriate contingency plan should HCFA or its contractors be unable to either process claims or distribute payments in the Y2K transition. The GAO points out that this might affect the quality of health care and urges Congress to pass legislation authorizing a contingency plan for HCFA. The suggestion has also been made that HCFA issue payments in advance of Jan. 1, 2000, based on past payment levels, allowing providers to continue operating should Y2K interrupt reimbursement payments.