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ICD-10 Implementation

Although this release of ICD-10-CM is now available for public viewing, the codes in ICD-10-CM are not currently valid for any purpose or use. The effective implementation date for ICD-10-CM (and ICD-10-PCS) is October 1, 2013. Updates to this version are anticipated prior to implementation of ICD-10-CM.

ICD-10-CM Final Rule: Making the Transition

On January 16, 2009, HHS published two final rules to adopt updated HIPAA standards; these rules are available at the Federal Register.

In one rule, HHS is adopting X12 Version 5010 and NCPDP Version D.0 for HIPAA transactions. In this rule, HHS also adopts a new standard for Medicaid subrogation for pharmacy claims, known as NCPDP Version 3.0. For Version 5010 and Version D.0, the compliance date for all covered entities is January 1, 2012. This gives the industry enough time to test the standards internally, to ensure that systems have been appropriately updated, and then to test between trading partners before the compliance date. The compliance date for the Medicaid subrogation standard is also January 1, 2012, except for small health plans, which will have until January 1, 2013 to come into compliance.

In a separate final rule, HHS modifies the standard medical data code sets for coding diagnoses and inpatient hospital procedures by concurrently adopting the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for diagnosis coding and the International Classification of Diseases, 10th Revision, Procedural Coding System (ICD-10-PCS) for inpatient hospital procedure coding. These new codes replace the current International Classification , 9th Revision, Clinical Modification, Volumes 1 and 2 and the International Classification , 9th Revision, Clinical Modification, Volume 3 for diagnosis and procedure codes respectively. The implementation date for ICD-10-CM and ICD-10-PCS is October 1, 2013 for all covered entities.

Version 5010 accommodates the ICD-10 code sets, and has an earlier compliance date than ICD-10 in order to ensure adequate testing time for the industry. These two rules apply to all HIPAA covered entities, including health plans, health care clearinghouses, and certain health care providers.

ICD-10 / Version 5010 Industry Listening Session Summary

On December 8, 2009, CMS invited representatives of the health care industry to convene in Washington D.C. for a listening session on the transition to ICD-10, and issues associated with the changeover to the Version 5010 standards for HIPAA administrative transactions. The purpose of this session was to get industry feedback on key issues related to the implementations. This included:

• Identifying areas that require a consistent approach and implementation;
• Fostering discussion for partnering opportunities between organizations and CMS to promote best practices;
• Initiating meaningful messaging to the respective organizations' constituents;
• Ensuring that ICD-10 planning and implementation is prioritized within their sectors;
• Leveraging your communication vehicles to help reach plans and providers; and
• Aligning implementation strategies as applicable and appropriate.

CMS ICD-10 Impact Analysis

In September 2008, CMS concluded a one year project with the American Health Information Management Association (AHIMA) to identify and assess the business processes, systems and operations under CMS' direct responsibility that would potentially be impacted by a transition to the ICD-10 code set. The analysis included information gathered from CMS components from late 2007 to early 2008 and was the first of several efforts that will be undertaken to prepare CMS for the transition to ICD-10. An initial summary of AHIMA's executive report is included in the Downloads section below, along with a more detailed report of AHIMA's initial findings.

The second phase of planning was initiated in September 2008 by Noblis, and was built upon AHIMA's findings to include the impacts and risks surrounding new legislation and initiatives not accounted for in the AHIMA study as well as updated needed from the original analysis.

This ICD-10 Impact Analysis further analyzes the impact of the transition from ICD-9 to ICD-10 on CMS policies, processes and systems by confirming where CMS uses ICD codes, discussing the opportunities that ICD-10 presents to CMS, assessing the risks, and describing the high level effort required to prepare CMS for the transition to ICD-10. Additionally, this document identifies risk mitigation strategies to reduce the consequences of potential negative events associated with the transition. This report also describes the high level activities required of each CMS component to prepare for ICD-10. To view the analysis, please see the link in the Downloads section below.

Although the Impact Analysis was intended to be solely CMS-focused, the agency is committed to sharing the report to provide insights for ICD-10 planning and implementation activities in other organizations. We will continue to share information regarding ICD-10 implementation as is it becomes available.

ICD-10-CM is maintained by the National Center for Health Statistics (NCHS).

ICD-10-PCS is maintained by the Center for Medicare & Medicaid Services (CMS).