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Frequently Asked Questions

Don't see your question? Email your question to AHIMA at icd10questions@ahima.org and check here often for FAQ updates as AHIMA is constantly building the pool of Q&As.

ICD-10

ICD-10-CM and ICD-10-PCS

ICD-10-CM

ICD-10-PCS

Alternatives to Adopting ICD-10-CM and ICD-10-PCS

Implementation/Transition

Mapping

Training and Resources

ICD-10

Q: What is the International Classification of Diseases (ICD)?

A: It is a classification system developed and maintained by the World Health Organization (WHO). The WHO is the directing and coordinating authority for health within the United Nations system and is chiefly responsible for providing leadership on global health matters, setting standards, providing technical support to countries and monitoring health trends.  The ICD is an international standard diagnostic classification system providing the basis for national morbidity and mortality statistical data collection to improve the management of healthcare. It is used to classify diseases and other health conditions that are documented on various types of medical records. Over the years, the use of the ICD for indexing hospital medical records increased rapidly and some countries have prepared national adaptations which provide the additional detail needed for a specific application of the ICD.   

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Q:
What classification system do other countries use for medical coding?

A: Most of the rest of the world is using ICD-10 or a clinical modification of ICD-10.  The US is the only industrialized nation not using an ICD-10-based classification system for morbidity reporting.

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Q:
Why does it matter if the rest of the world is moving to ICD-10?

A:  If we do not adopt ICD-10, we will not have compatible data to compare internationally.  As many other countries have already moved to ICD-10, we will be capturing morbidity data using the outdated classification system, ICD-9-CM.  This has already led to problems identifying and tracking new health threats.  It will severely limit our ability to compare outcomes of new technologies used in the U.S. and abroad.  It will also limit our ability for surveillance and to develop and quickly respond to interventions for emerging diseases.  We are a global community, it is vital that our health care data represent current medical conditions and technologies and that it is compatible with the international version of ICD-10.  Some of these are:

Example:  Identifying and tracking diseases impacted by anthrax, severe acute respiratory syndrome (SARS), and Monkeypox are increasingly important in our global community.

Example:  Since the U.S. moved to using ICD-10 for coding mortality data (for death certificates) in 1999, state specific mortality data (ICD-10) cannot be easily compared to hospital morbidity data (ICD-9-CM) to track this with leading causes of death. Additional information on mortality data is available at http://www.cdc.gov/nchs/deaths.htm.

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ICD-10-CM and ICD-10-PCS

Q:  Where can I find resources on ICD-10-CM and ICD-10-PCS? 

A:  There are many good resources available, beginning with the ICD-10 NPRM, which can be accessed at:  www.access.gpo.gov/su_docs/fedreg/a080822c.html.  ICD-10-CM information can be found on the NCHS website: http://www.cdc.gov/nchs/about/otheract/icd9/icd10cm.htm. ICD-10-PCS information can be found on the CMS website: http://www.cms.hhs.gov/ICD10/.  A number of ICD-10 resources are also available on the AHIMA Web site at http://www.ahima.org/icd10.

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Q:  What are the main reasons why we should move from ICD-9-CM to ICD-10-CM and ICD-10- PCS?

A:  There are two main reasons:
1.  Payors cannot pay claims fairly using ICD-9-CM since the classification system does not accurately reflect current technology and medical treatment.  Significantly different procedures are assigned to a single ICD-9-CM procedure code.  Limitations in the coding system translate directly into limitations in the diagnosis-related groups (DRG). 
2.  The healthcare industry cannot accurately measure quality of care using ICD-9-CM.  It is difficult to evaluate the outcome of new procedures and emerging health care conditions when there are not precise codes.  Most importantly, we have a mission to improve our ability to measure health care services provided to our patients, enhance clinical decision-making, track public health issues, conduct medical research, identify fraud and abuse and design our payment systems to ensure services are appropriately paid.

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Q:  Is switching to ICD-10-CM and ICD-10-PCS really necessary?

A:  Yes. The U.S. needs to switch to ICD-10-CM and ICD-10-PCS in order to improve the quality of our nation's health care data and to maintain clinical data comparability with the rest of the world. The longer we continue to use International Classification of Diseases, 9th Edition, Clinical Modification (ICD-9-CM), the more difficult it becomes to compile and share accurate disease and mortality data at a time when such global data sharing is critical for public health and safety. The better data provided by ICD-10-CM and ICD-10-PCS will lead to improved patient safety, quality of care, and public health and bio-terrorism monitoring. 

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Q:  What will happen if we do not adopt ICD-10-CM and ICD-10-PCS?

A:  ICD-9-CM will increasingly run out of codes for diagnoses and certain types of procedures and codes will become more vague.  CMS and NCHS will have to continue to create new codes in inappropriate sections of the book and will have to make compromises on the level of specificity they are able to incorporate.  Deterioration in the basic structure and hierarchy make it difficult for physicians and coders to assign accurate ICD-9-CM codes.  Examples of procedure codes that were created outside of their appropriate section of ICD-9-CM are: 

  • Code for Administration of inhaled nitric oxide is not in the same area as other respiratory therapy codes.
  • Code for new biotechnology product, which is indicated for the reduction of mortality in adult patients with severe sepsis and qualified for a Medicare New Technology add-on payment, is not in the same area as other infusions.
  • Code for insertion of non-coronary drug eluting artery stents is not in the section with other stents, and is not in the cardiovascular part of the book.
  • Code for new type of combination defibrillator pacemaker device is not in the same chapter as the other defibrillator and pacemaker devices.

Since many of these new codes involve new technology, we will have poor data on the use of new technology and patient outcomes as coders try to find codes in unusual parts of the coding book and attempt to choose the closest possible procedure code to describe the procedure.  Hospitals are spending more administrative time attempting to assign a code when existing codes do not adequately describe the procedure.  These problem cases often involve new technology for which there is no clear correct and descriptive ICD-9-CM procedure code. 

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Q:  Why are there two systems, ICD-10-CM and ICD-10-PCS, when there was only one system for ICD-9-CM?

A:  The new ICD-10 systems were developed by NCHS and CMS under different timeframes.  When ICD-10-CM and ICD-10-PCS are implemented, the two systems may be jointly called ICD-10-CM and include diagnoses and procedures.  The ICD-9 systems were separately developed by NCHS and CMS, but referred to jointly as ICD-9-CM.  It is anticipated that the current maintenance process for ICD-9-CM will be used for ICD-10-CM and ICD-10-PCS. 

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Q:  What is the benefit of having so many more codes?

A:  There are a number of areas within the ICD-9-CM where the country could benefit from the greater detail provided by having more extensive codes.  While there is greater specificity offered in the majority of the ICD-10-PCS codes, there will continue to be options for broader, generalized codes when the specific details regarding a patient's condition may not be known or documented. Additionally, the ICD-9-CM classification has not kept up with medical knowledge. 
Some examples are as follows:

Example:  ICD-9-CM does not accurately reflect current technology and medical treatment.  Since ICD-9-CM does not accurately describe advancements in technologies, significantly different procedures are assigned to a single ICD-9-CM procedure code.  Limitations in the coding system translate directly into limitations in coverage and reimbursement. 

Example:  CMS has had difficulties identifying and paying for new technology.  This has been a particular problem in the cardiovascular and orthopedic parts of ICD-9-CM where many categories have no room for more ICD-9-CM codes.  Some of the recent problems have included new devices used in spinal fusions, new cardiac defibrillator devices, and drug eluting stents, among others.

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Q:  Are ICD-10-CM and ICD-10-PCS used internationally?

A:  No. Only ICD-10 is used internationally.  Some countries have their own clinical modifications of ICD-10 to better meet their needs.  For those countries that code procedures, various coding systems are used.

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Q:  Are there any ICD-10 benefits that relate to building an electronic medical record?

A:  Yes, ICD-10-CM and ICD-10-PCS present a number of benefits to building an electronic medical record.  Both ICD-10-CM and ICD-10-PCS are better suited for use in electronic health record systems because they permit more robust mapping from Systematized Nomenclature of Medicine-Clinical Terms (SNOMED-CT) clinical reference terminology and are more amenable to computer-assisted coding. 

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Q:  How might the implementation of ICD-10-CM and ICD-10-PCS be expected to impact quality reporting? 

A:  Data and systems used to collect quality performance measures for all provider types would be revised to accommodate ICD-10-CM and ICD-10-PCS codes.  The ICD-10 coded data will permit a better assessment of patient severity, the intensity and complexity of services provided to patients, and the resources utilized in caring for patients.  It is anticipated that this data will inform future program and payment policies.  Current quality measures would be replaced with codes from the new coding systems. 

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Q:  What impact will ICD-10-CM and ICD-10-PCS have on fraud and abuse prevention and detection?

A:  The use of ICD-10-CM and ICD-10- PCS may help reduce the opportunities for fraud and improve fraud detection capabilities.  Field testing has shown that ICD-10's greater specificity results in improved data accuracy and coding due to the level of detail in the code descriptors.   The improved logic and increased specificity in ICD-10 will facilitate the development of sophisticated edit tools for detection of questionable patterns and suspected fraud, whereas continued use of ICD-9-CM inhibits the development of computer-assisted coding systems that can reduce fraud. The report of the anti-fraud study conducted by the Office of the National Coordinator for Health Information Technology (ONC) is available at http://www.hhs.gov/healthit/documents/ReportOnTheUse.pdf.

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Q:  Do coders find it harder to code with ICD-10-CM and ICD-10-PCS?

A:  In the American Hospital Association/American Health Information Management Association (AHA/AHIMA) ICD-10-CM Field Testing Project, 76% of the participants stated that ICD-10-CM is an improvement over ICD-9-CM. The test results found that ICD-10-CM codes can be applied to today's medical records in a variety of health care settings without having to change documentation practices, although improved documentation would result in higher coding specificity and, therefore, higher data quality in some cases.  To access the ICD-10-CM Field Testing Project Report on Findings, visit http://www.ahima.org/icd10/documents/FinalStudy_000.pdf. In the findings from the Clinical Data Abstraction Centers (CDAC) testing of ICD-10-Procedure Coding System (PCS), it was identified as more complete than ICD-9-CM with greater specificity, easy to expand, and easier to analyze because of its multiaxial structure.  CDAC testing also found that standardized terminology makes it easier to use once the coder has initial training, and having all terms defined makes it easier to teach.  To find additional information about CDAC testing, visit http://www.cms.hhs.gov/ICD10/02_ICD-10-PCS.asp (see the PowerPoint slide presentation).

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Q:  What type of testing has been done on ICD-10-CM and ICD-10-PCS?

A:  Both systems have undergone formal testing. The World Health Organization (WHO) field tested the ICD-10 chapters where radical changes were made (e.g., Mental and Behavioral Disorders, Injuries, External Causes of Morbidity and Mortality). CMS conducted a formal test of ICD-10-PCS using Clinical Data Abstraction Centers (CDAC), a CMS contractor.  Formal testing of ICD-10-CM has been conducted by the CDAC, the American Hospital Association (AHA), and the American Health Information Management Association (AHIMA).  Testing involved coding actual medical records using both ICD-9-CM and either ICD-10-CM or ICD-10-PCS.  The testing of ICD-10-PCS focused on hospital inpatient records (since that is where it is intended to be used), whereas the testing of ICD-10-CM involved medical records from multiple types of health care settings

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Q:  Is there a cost of staying with ICD-9-CM? 

A:  An antiquated system has a negative impact on the health care system in the U.S.  Being unable to uniquely capture new technologies and services as well as new disease and medical knowledge severely restricts data analysis on national health care policies.  It may also restrict the ability to analyze the services provided to patients and whether or not they are equitably reimbursed.  Lack of data on outcomes may have a significant impact on health care delivery decisions.  Those who provide, reimburse, and utilize health care services must reach a mutual decision on whether the costs saved by staying with the current system override the potential problems from not having accurate health care data. 

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ICD-10-CM

Q:  What is the International Classification of Diseases, 10th Edition, Clinical Modification (ICD-10-CM)?

A:  It is the most current diagnosis classification system developed for use in the United States.  Currently, in the United States, providers in all healthcare settings use diagnostic codes for reporting conditions, symptoms and diseases using ICD-9-CM.  Upon implementation of ICD-10-CM, these same providers would begin to use the new classification system for reporting conditions, symptoms and diseases for data collection, payment policy, research and other purposes.

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Q:  Who maintains ICD-10-CM?

A:  ICD-10-CM was developed and is maintained by NCHS under authorization by the World Health Organization (WHO).  The current version is July 2007.  ICD-10-CM information is available at http://www.cdc.gov/nchs/about/otheract/icd9/icd10cm.htm on the Internet.

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Q:  What is the difference between International Classification of Diseases, 10th Edition (ICD-10) and ICD-10-Clinical Modification (ICD-10-CM)?

A:  The clinical modification (CM) was necessary to incorporate the level of detail needed in a morbidity classification and to support U.S. data needs.  In the U.S. we have a mission to improve our ability to measure health care services provided to our patients, enhance clinical decision-making, track public health issues, conduct medical research, identify fraud and abuse and design our payment systems to ensure services are appropriately paid.  By creating the CM it will enable the US to meet these needs.

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Q:  Is ICD-10-CM similar to ICD-9-CM diagnosis coding or is it completely different?

A:  As illustrated below, there are similarities between ICD-10-CM and ICD-9-CM diagnosis codes; however there are also distinct differences.  The actual coding process remains the same.


ICD-9-CM

ICD-10-CM

3-5 characters

3-7 characters

First character is numeric or alpha (E or V)

First character is alpha

Characters 2-5 are numeric

Characters 2-7 are alpha or numeric

Always at least 3 characters

Always at least 3 characters

Use of decimal after 3 characters              

Use of decimal after 3 characters

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Q:  How many ICD-10-CM diagnosis codes are there compared to ICD-9-CM diagnosis codes?

A:  As of 2008, there are 68,064 ICD-10-CM codes while ICD-9-CM has 13,677.  Providers in all healthcare settings currently utilize ICD-9-CM diagnosis codes to report various conditions, diseases or symptoms as required under the Health Insurance Portability and Accountability Act (HIPAA).  In the future, these same providers will utilize ICD-10-CM diagnosis codes for reporting, payment, policy decisions, research, and other purposes. 

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Q:  Why are there so many more codes in ICD-10-CM than in ICD-9-CM?

A:  ICD-10-CM was developed through a close collaboration with physician specialty groups who reviewed the basic ICD-10 as developed by the World Health Organization (WHO) and identified areas where greater detail was needed. The greater detail and increased number of codes found in ICD-10-CM was the direct result of requests from these specialty groups who recognized the importance of identifying and capturing information on health care conditions. The added detail was felt to be important in tracking health care trends, analyzing quality issues, and evaluating outcomes for a variety of health care technologies and treatments. Many areas of greater code specificity were the result of requests from physicians who wanted to provide more information in the codes in order to reduce the number of paper documents being sent to support their bills.

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Q:  What's wrong with the ICD-9-CM diagnosis coding system?

A:  ICD-9-CM was developed 30 years ago and is obsolete because it cannot accurately describe diagnoses at the necessary level of detail needed for the management of our healthcare system in the 21st century.  In addition, a number of countries have already moved to ICD-10. Therefore, the statistics reported for diagnosis codes will be flawed since there is no compatible data to compare internationally. We will be capturing morbidity data using an outdated classification system, which can potentially cause problems identifying and tracking new health threats (e.g., SARS, anthrax).   

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Q:  Is ICD-10-CM mainly intended for hospital inpatient coding?

A:  No, ICD-10-CM will replace ICD-9-CM diagnosis codes and will be used for reporting all diagnoses.  Providers in all healthcare settings currently utilize ICD-9-CM diagnosis codes to report various conditions, diseases or symptoms as required under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and in the future these same providers will utilize ICD-10-CM diagnosis codes for reporting, payment, research, and other purposes. 

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Q:  Why is ICD-10-CM better than ICD-9-CM?

A:  As indicated above, ICD-10-CM contains an increased number of codes and categories.  The increased code options will allow for greater precision and specificity to accurately represent current medical knowledge and allows the flexibility for expansion to add future medical diagnoses.  Improvements in the accuracy and quality of the coded data will lay the foundation to make more informed decisions regarding our nation's healthcare.

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ICD-10-PCS

Q:  What is the International Classification of Diseases, 10th Edition, Procedure Coding System (ICD-10-PCS)?

A:  It is the most current procedure classification system developed for use in the United States.  Each code is procedure specific with standardized terminology which will provide significant improvements for data collection and research, resulting in improved payments and outcomes measures.

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Q:  Who maintains ICD-10-PCS?

A:   CMS developed and maintains ICD-10-PCS.  ICD-10-PCS information is available at http://www.cms.hhs.gov/ICD10 on the Internet.

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Q:   Will ICD-10-PCS affect physician office billing?

A:  No, ICD-10-PCS will not be used in physician offices.  ICD-10-PCS will be used only for inpatient billing by hospitals.  Physicians will continue to use Current Procedural Terminology® (CPT®) and Healthcare Common Procedure Coding System (HCPCS) to bill for their services.

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Q:  Will ICD-10-PCS affect ambulatory care providers?

A:  No, ICD-10-PCS will not be used in ambulatory settings.  These providers will continue to use Current Procedural Terminology® (CPT®) and Healthcare Common Procedure Coding System (HCPCS) to bill for their services.

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Q:  How many ICD-10-PCS codes are there compared to ICD-9-CM procedure codes?

A:  As of 2008, there are 86,916 ICD-10-PCS codes while ICD-9-CM has 3,768 procedure codes.  The increase in the number of codes allows greater detail and flexibility in the classification system overall.   While the ICD-10-PCS is representative of current treatment modalities it remains expandable to add future medical technology, procedures or services.

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Q:  Is ICD-10-PCS similar to ICD-9-CM procedure coding or is it different?

A:  The structure of ICD-10-PCS and ICD-9-CM is different.  ICD-9-CM procedures have 3 or 4 numeric digits.  ICD-10-PCS has 7 alpha or numeric digits providing greater precision and specificity. The added detail will maximize the value of clinical data and result in the benefit of an interoperable electronic health records system among many other benefits.  In ICD-10-PCS, the letters I and O are not used so there is no confusion about the numbers 1 and 0. 

ICD-9-CM

ICD-10-PCS

3-4 characters (always at least 3 characters)

7 characters

All characters are numeric

 Each character can be alpha or numeric (alpha characters are not case-sensitive)

Use of decimal after 2 characters

No decimal

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Q:  Due to the changes in ICD-10-PCS that require more codes to report some procedures, will CMS accept more than five additional inpatient procedure codes on the hospital claim?

A:  AHIMA understands that CMS is currently evaluating the expansion of the number of codes processed once version 5010 of the electronic healthcare transaction standards is adopted.

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Alternatives to Adopting ICD-10-CM and ICD-10-PCS

Q:  Why can't CMS simply expand the systemic-9-CM procedure coding system to capture new technology?

A:  Hospitals are having increased difficulty using the ICD-9-CM procedure code system.  Since there are limited areas for expansion, new codes are sometimes created in different sections of the coding book.  This leads to problems for the coders in finding and assigning codes for new technologies.  When there are specific procedure codes for new technologies, payers can evaluate whether or not they want to pay for the new technology and evaluate how much the technology costs based on billing data.  When there are not specific codes for the new technology, providers do not know if they are in fact paying for the new technology.  Hospitals will use existing codes to capture the new technology.  

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Q:  Why doesn't CMS just add an additional digit to ICD-9-CM procedures or change some of the digits to alpha characters?

A:  Taking the existing system and simply adding more digits would involve the same systems costs as simply moving to a new, logical system with an increased number of digits.  Some industry representatives have stated that the suggested approach amounts to putting a new transmission into a 10-year-old car whose engine is worn out.  There is no point putting a new transmission into a car whose engine is shot (with the exception of collectors who do not actually use the car as their primary source of transportation).  It has outlived its usefulness and at some point, you have to make the investment to buy a new car.  We cannot afford to maintain a coding system that has outlived its usefulness.   CMS evaluated a number of options for updating ICD-9-CM procedures.  These were discussed at public meetings of the ICD-9-CM Coordination and Maintenance Committee.  There was no support for adding an additional digit to the current ICD-9-CM procedure codes.  System costs to expand the field size would not be countered by an improvement in the coding system and would only increase the cost and inefficiency of maintaining an antiquated coding system.  Since the base system was designed in the mid 1970s, the basic structure, terms, and approaches are based on outdated technology.  There would be a need for radical changes of the basic system.  The disruption resulting from adding a digit and then trying to refine and modify approaches and terms would result in nearly the same costs in infrastructure and systems changes but would not be balanced by a significant improvement in the coding system.  Simply adding alpha characters to the current coding system has also been suggested.  It was not felt that this revision could overcome the outdated terms, approaches, and organization of ICD-9-CM.

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Q:  Can Systematized Nomenclature of Medicine-Clinical Terms (SNOMED-CT®) be used for coding instead of ICD-10?

A:  No. SNOMED-CT® cannot replace ICD-10 since SNOMED-CT is not a coding system.  SNOMED-CT and ICD-10 systems are designed for different uses in the health care system. ICD-10-CM and ICD-10-PCS are needed to facilitate retrieval of coded data at the desired level of detail depending on the purposes for which the data are being used. A clinical terminology such as SNOMED-CT® lack the ability to provide the necessary details and specificity needed and found in classification systems for administrative reporting such as statistical reporting and reimbursement.

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Q:  Since the World Health Organization (WHO) is already working on International Classification of Diseases, 11th Edition (ICD-11), why would we not just implement ICD-11 instead of ICD-10?

A:  No firm timeframes for the completion of ICD-11 developmental work or testing have been identified, and no firm implementation date for ICD-11 has been designated. This means the earliest projected date for ICD-11 implementation would be 2020, assuming that no US clinical modification is needed. Also, since ICD-11 will build upon ICD-10, many of the costs and much of the work associated with upgrading to ICD-11 will be mitigated by ICD-10 implementation. ICD-10, not ICD-9, is the pathway to ICD-11.

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Implementation/Transition

Q:   What date will the U.S. have to start using ICD-10-CM and ICD-10-PCS?

A:  The Centers for Medicare & Medicaid Services has released a final rule for replacing the 30-year-old ICD-9-CM code set with ICD-10-CM and ICD-10-PCS.  The final rule outlines the effective date as 60 days after publication in the Federal Register, and the compliance date for the two classification sets is established as October 1, 2013. A second rule related to the HIPAA transaction standards €“ X12 version 5010 and NCPDP version D.0  establish earlier effective dates, with the latest being January 1, 2013.  The HIPAA transactions software must be updated to accommodate the use of the ICD-10-CM and ICD-10-PCS code sets.

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Q:  Will the benefits of ICD-10-CM and ICD-10-PCS really outweigh the costs of implementation?

A:  An independent study conducted by RAND concluded that the benefits of ICD-10-CM and ICD-10-PCS are likely to exceed initial implementation costs within just a few years. Furthermore, the cost of doing nothing may be greater than actual implementation. Any delay in adoption of ICD-10-CM and ICD-10-PCS will cause an increase in future implementation costs as the management of health information becomes increasingly electronic and the costs of implementing new coding systems increase due to required systems and applications upgrades.

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Q:  Will all providers and payers begin using ICD-10-CM at the same time?

A: In the ICD-10 NPRM, the Department of Health and Human Services (HHS) proposes a single compliance date for all covered entities.  They believe it is in the industry's best interest to have a single compliance date for ICD-10-CM and ICD-10-PCS. This would reduce burden on both providers and insurers who would be able to edit on a single new coding system for claims received for encounters and discharges occurring on or after the implementation date. Hospitals and many other providers have requested that ICD-10-CM and ICD-10-PCS be implemented at the same time and not phased in.  They have stated that it would be least disruptive to conduct all training, systems changes, and other administrative changes at the same time for both new coding systems. 

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Q:  Will there be a phase-in time period for ICD-10-CM and ICD-10-PCS where providers can use either ICD-9-CM or the ICD-10 based coding systems?

A:  The ICD-10 NPRM proposes a set date on which all providers, payers, and data users will implement ICD-10-CM and ICD-10-PCS for the prescribed date of service.  The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Transactions and Code Sets Rule requires that medical data codes that are valid at the time health care is furnished be used for reporting services. For inpatient claims, the date of discharge is used as the date to determine valid medical codes and other codes that are dependent upon service date for validity. For outpatient claims, the actual date that the service was rendered is reported with the service item at the line level and used to determine valid medical codes and other codes that are subject to service date for validity.

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Q:  After the implementation of ICD-10-CM and ICD-10-PCS, will providers stop reporting ICD-9-CM codes on claims?

A:  The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Transactions and Code Sets Rule requires that medical data codes that are valid at the time health care is furnished be used for reporting services. For inpatient claims, the date of discharge is used as the date to determine valid medical codes and other codes that are dependent upon service date for validity. For outpatient claims, the actual date that the service was rendered is reported with the service item at the line level and used to determine valid medical codes and other codes that are subject to service date for validity.

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Q: Won't switching to using ICD-10-CM and ICD-10-PCS be complicated for coders?

A:  An American Health Information Management Association/American Hospital Association (AHIMA/AHA) field testing study shows that ICD-10-CM can be implemented without excessive staff training costs or changes in documentation practices. Due to the logical structure and standardized terminology, ICD-10-PCS is easier to learn than ICD-9-CM procedure coding. Training ICD-9-CM users to use ICD-10-CM and ICD-10-PCS has been shown to be relatively straightforward.

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Q:  How long will it take coders to become proficient in using ICD-10-CM?

A:  Proficiency in use of the system will be dependent on a number of factors, including level of coder education and experience.  However, it is anticipated that most coders will have a high level of proficiency within 6 months of use of ICD-10-CM and ICD-10-PCS.

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Q: Why does electronic transaction standard version 5010 have to be implemented before ICD-10-CM and ICD-10-PCS?

A: The current version of the standard for electronic healthcare transactions, known as version 4010/4010A1 does not accommodate the ICD-10 code sets, whereas the updated version, known as version 5010, does. Additional information regarding version 5010 is available at http://www.cms.hhs.gov/TransactionCodeSetsStands/02_TransactionsandCodeSetsRegulations.asp.

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Q:  How will the implementation of ICD-10-CM and ICD-10-PCS change the Medicare prospective payment systems (PPS)? 

A:  CMS has indicated that, initially, PPS case mix groups that rely on diagnosis and procedure codes (e.g., Medicare severity diagnosis-related groups, Home Health Resource Groups) may not fundamentally change. Mapping methodologies will be used to map the ICD-10-CM and ICD-10-PCS codes to the case mix group where the corresponding ICD-9-CM code was assigned. In cases when there is not a straightforward map, CMS will select the case mix group that is believed to be the "best fit." Once CMS has collected sufficient claims data coded in ICD-10-CM and ICD-10-PCS, appropriate refinements will be made to the case mix groups as warranted.

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Q:  Will the State Medicaid Program be required to update their computer systems to utilize ICD-10-CM and ICD-10-PCS codes?

A: Yes.  The Health Insurance Portability and Accountability Act of 1996 (HIPAA) requires that there be one official list of national medical code sets.

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Q:  Will all providers have to renegotiate their contracts with payers if ICD-10-CM and ICD-10- PCS are implemented?

A:  No, payers could continue to reimburse providers based on existing payment policies.  They would simply update these policies using ICD-10-CM and ICD-10-PCS codes.  Payers routinely update their existing payment policies each year as a result of the annual updating of the coding system.  CMS is planning to map the new coding systems into its current diagnosis-related group (DRG) system.  Therefore, hospitals should arrive at the same MS-DRG assignment even though a new coding system is used.  There may be a small number of cases where this is not possible because of combination codes within the ICD-10-CM diagnosis system.  These cases will be handled on an individual basis, and the most appropriate MS-DRG assignment will be proposed.

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Q:  How will software vendors manage to implement ICD-10-CM and ICD-10- PCS within their software?

A:  Many major software vendors have indicated that they have already made provisions for ICD-10-CM and ICD-10-PCS and need only a reasonable implementation schedule to make the transition.  Several vendors already have experience with this process since they have worked with other countries that have implemented ICD-10.

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Q:  Are there lessons to be learned from other countries that have implemented ICD-10?

A:  Yes, other countries can help the U.S. prepare.  Some of the "lessons learned" are: 
- Begin now - take advantage of lead time
- Adequate planning and preparation are very important
- There is likely to be a 6-month learning curve
-Training should not exceed 6 months before implementation and use
- Vendor readiness is extremely important
- Communication is critical
- Appropriate education targeted at the various stakeholder groups is critical
- Expect significant ICD-9/ICD-10 data comparability issues due to the fundamental differences in the coding schemes                                                                                   

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Q:  What can facilities do now to help prepare for ICD-10-CM and ICD-10-PCS? 

A:  Organizations and facilities can plan for implementation of ICD-10-CM and ICD-10-PCS by developing an organizational plan that includes:
Situational Analysis:
- Identify stakeholders
- Impact assessment
- Strategy formation/goal identification
- Educational plan for employees at all levels
- Develop information systems/technology systems change implementation plan that includes testing and "go live" dates
- Plan for documentation changes

Strategic Implementation/Organizing:
- Acquire resources to implement the plan
- Evaluate financial impact on organization

Planning for Strategic Control:
- Develop objectives
- Plan measurement tools
- Plan evaluation strategies
- Plan action steps for implementation

Many professional organizations and business have resources available to help with ICD-10-CM and ICD-10-PCS implementation planning.  AHIMA has an ICD-10 Preparation Checklist available at http://www.ahima.org/icd10/icd-10PreparationChecklist.mht.

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Mapping

Q: Are maps available between ICD-9-CM and ICD-10-CM diagnosis codes? 

A: Yes, maps are available between ICD-9-CM and ICD-10-CM and between ICD-10-CM and ICD-9-CM.  These maps will facilitate longitudinal data analysis.  To access the maps, visit http://www.cdc.gov/nchs/about/otheract/icd9/icd10cm.htm.

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Q: Are maps available between ICD-9-CM and ICD-10-PCS procedure codes? 

A: Yes, maps are available between ICD-9-CM and ICD-10-PCS and between ICD-10-PCS and ICD-9-CM.  These maps will facilitate longitudinal data analysis. To access the maps, visit http://www.cms.hhs.gov/ICD10/.

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Q:  Are there any guidelines that assist with the mapping between ICD-9-CM and ICD-10-CM and ICD-10- PCS?

A: Yes, General Equivalence Mappings (GEM) documents, also referred to as crosswalks and mappings, are available for diagnoses and procedures.  These documents are a 2007 Version Documentation and User's Guide that are available at  http://www.cms.hhs.gov/ICD10/ and http://www.cdc.gov/nchs/about/otheract/icd9/icd10cm.htm on the Internet.

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Training and Resources

Q: Who needs education on ICD-10-CM and ICD-10-PCS?

A:  The following may need some amount of education on the structure, benefits and changes seen in ICD-10-CM and ICD-10-PCS:
-  Health information management staff responsible for health record services
-  Billing or financial office professionals
-  Accounting professionals
-  Corporate compliance office staff
-  Auditors and/or consultants who perform documentation or coding review
-  Clinicians
-  Clinical department managers
-  Quality management staff
-  Utilization management staff
-  Patient access and registration staff (if they are involved in medical necessity determinations)
-  Ancillary department staff (e.g., physical therapists, occupational therapists,      respiratory therapists)
-  Visiting nurses
-  Hospice professionals
-  Nursing facility personnel
-  Outpatient service billing personnel
-  Data quality management staff
-  Data security personnel
-  Data analysts working both inside and outside the organization
-  Researchers
-  Other data users (e.g., performance improvement)
-  Information technology and information systems personnel

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Q:  Who will offer training on ICD-10-CM and ICD-10-PCS, and what type of training will be offered?

A:  A number of professional organizations and vendors will likely offer training on ICD-10-CM and ICD-10-PCS. Organizations may offer training on ICD-10-CM and ICD-10-PCS in various formats such as web-based training courses; in-person training classes; audio sessions; and CD-ROM, downloadable, and print materials.  AHIMA is developing a targeted educational model with education specifically marked toward educators, trainers, HIM leadership, the industry, students, data managers and users, coding personnel and providers. 

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Q:  How difficult will it be for coders to learn to use ICD-10-CM and ICD-10- PCS?

A:  The American Health Information Management Association (AHIMA) and the American Hospital Association (AHA) have conducted field tests of ICD-10-CM and found that training ICD-9-CM users to use ICD-10-CM is relatively straightforward.  ICD-10-CM retains the traditional ICD format and many of the same conventions.  New training methods and the internet should support cost-effective retraining of coders.  AHIMA, AHA, and CMS contractors have tested ICD-10-PCS and found that while it is significantly different from ICD-9-CM procedures because of logic of the system and standardized terminology, training can be accomplished within several days. 

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Q:  How many hours of intense coding training will be required?

A:  As a result of the American Hospital Association/American Health Information Management Association (AHA/AHIMA) ICD-10-CM Field Testing Project, the conclusion was that a maximum of 16 hours of training may be sufficient for experienced coding professionals on ICD-10-CM.  Physician practices may not need as much training due to the fact that they may utilize a limited number of codes.  To access the ICD-10-CM Field Testing Project Report on Findings, visit http://www.ahima.org/icd10/documents/FinalStudy_000.pdf on the Internet. It is estimated that the ICD-10- PCS will likely require an additional 16-24 hours of training.

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Q:  How long before implementation, should intense coder training be provided? 

A:  According to the American Hospital Association/American Health Information Management Association (AHA/AHIMA) ICD-10-CM Field Testing Project, the majority of participants believed training should be provided 3-6 months prior to ICD-10-CM implementation as supported by the Field Testing Report. To access the ICD-10-CM Field Testing Project Report on Findings, visit http://www.ahima.org/icd10/documents/FinalStudy_000.pdf on the Internet.

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Q:  How difficult will it be for physicians and their staff to learn how to use ICD-10-CM in order to bill for their services?

A:  ICD-10-CM is not a radical departure from ICD-9-CM in its organization and structure.  It has a maximum of seven digits as opposed to a range of three to five digits as is found in ICD-9-CM.  ICD-10-CM has significantly more codes because of the greater detail.  The American Hospital Association and the American Health Information Management Association (AHA/AHIMA) have performed some field testing on ICD-10-CM and found that 16 hours of training in ICD-10-CM would be required for a coding professional to learn the entire system.  However, many physician offices will not need this level of training, as they will only be using a limited range of codes.  Specialists may continue their practice of preparing lists of the most frequent conditions they treat, along with the appropriate ICD-10-CM codes, which can be used to check off the more common conditions.  When a physician treats a condition that is not on the list, the office staff will need to look up the diagnosis code in the ICD-10-CM coding book or the encoder software.  Physicians can still utilize a charge ticket, superbill, fee ticket, or encounter form as they have done previously.  The previous ICD-9-CM codes would be replaced with ICD-10-CM codes.  Also, ICD-10-CM reflects increased specificity and logical placement of codes that medical specialty groups requested as well as improvements in current medical terminology. Examples of charge tickets updated to ICD-10-CM are available at http://www.ahima.org/icd10/understand.asp.

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