Web Exclusive: It’s not too early to begin preparing for ICD-10

By Sheila Madhani, assistant director of health policy

In January 2009, the Centers for Medicare and Medicaid Services (CMS) released final regulations related to the adoption of ICD-10-CM and ICD-10-PCS. These regulations will replace ICD-9 codes that are currently used by physicians and hospitals for coding diagnoses and inpatient hospital procedures. On October 1, 2013, all providers must report ICD-10-CM for diagnoses for all health transactions (Medicare and private payers). Physicians will continue to use CPT codes to report procedures. Hospital inpatient procedures will be reported using ICD-10-PCS. 

The International Classification of Diseases (ICD) was developed by the World Health Organization. Each individual country then adapts the code set to its own needs and preferences. The National
Center for Health and Vital Statistics (NCHVS), within the Centers for Disease Control and Prevention (CDC), is responsible for implementing ICD in the U.S. CMS is working with NCHVS to manage the implementation of ICD-10.

In communications to providers, CMS has emphasized that there will be no delays or grace periods to the established deadlines. ICD-9-CM codes will not be accepted for services provided on or after October 1, 2013. ICD-10 codes will not be accepted for services prior to October 1, 2013.

Rationale for change to ICD-10
The finalization of the adoption to ICD-10 is the culmination of an almost 10-year debate. While ICD-10 is already used by much of the rest of the world for morbidity and mortality statistics, there has been great resistance to the transition to ICD-10 here in the U.S. Concerns have been raised regarding the large increase in codes from ICD-9 to ICD-10, for diagnosis codes an increase from approximately 14,000 to about 70,000 codes, which could in turn increase the administrative burden of coding and documentation. The costs to upgrade systems and train staff in the new system have also been significant concerns.

CMS and other supporters of ICD-10 have touted the benefits of ICD-10 and it being a needed improvement for the more complex U.S. health care system of today. The push to ICD-10 was largely driven by concerns that ICD-9 had become outdated and room was running out to add new codes in many sections. In contrast, CMS views ICD-10 as providing better data for: clinical, financial and administrative performance improvement; designing more robust payment systems and processing claims for reimbursement; and monitoring resource utilization. All of the benefits cited above have also been cited in some fashion in discussions around health reform.

Differences Between ICD-9 and ICD-10
As stated previously, ICD-10-CM is a much larger code set. In addition to the difference in the number of codes there are also structural differences between the two code sets.

Below are some example comparisons to illustrate the structural differences between ICD-9-CM and ICD-10-CM. In certain circumstances, there are multiple ICD-10 codes for a diagnosis described by a single ICD-9 code.

Code updates and proposal for a code freeze
The ICD-9 and ICD-10 code sets are updated annually in October. Although ICD-10 is not yet implemented in the U.S., when changes are made to ICD-9 every year, parallel changes are made to ICD-10 to keep the code set up to date. These annual updates make transition planning challenging since a stable code set is needed to allow time for upgraded systems to be tested and staff to be trained in the new system. As a solution, a proposal to freeze updates to both ICD-9 and ICD-10 is being considered. The proposal currently being considered is:

• Last regular annual update to both ICD-9 and ICD-10 would be made on October 1, 2011.
• Only limited ICD-9 and ICD-10 updates for new technologies and diseases on October 1, 2012, and for ICD-10 on October 1, 2013.
• Regular annual updates to ICD-10 beginning October 1, 2014.

While providers and payers have publically supported a freeze, there is some concern within the vendor community that a code freeze could be harmful to the introduction of new technology. A final decision on the proposed code freeze will be announced at the September 15-16, 2010, meeting of the ICD-9 Coordinating and Maintenance Committee.

HIPAA Version 5010 Update
In addition to the transition to ICD-10 codes, CMS is also updating the transaction rules established for the electronic exchange of claims. Currently version 4010 of standards for electronic transactions is in place. By January 1, 2012, all systems must be updated to version 5010, which will be able to accommodate ICD-10. One of the benefits providers will experience with 5010 is an improvement in the submission process of claims submitted with additional medical documentation. Currently, when providers submit these claims they must be submitted manually. With 5010, while the documentation will still need to be submitted manually (i.e., via fax), the claim can be submitted electronically.

While the rule to update to version 5010 most directly impacts payers, a smooth transition to an updated version of standard transaction rules for electronic exchange of claims is relevant to providers because 5010 must be in place before ICD-10 codes can be accepted.

Preparing for the Transition
The first step for providers during this transition is to familiarize themselves with the new ICD-10 code set. A good place to begin is www.cms.gov/ICD10, where numerous resources have been posted. ASTRO encourages members to visit this website. 

Recently CMS released a MedLearn Matters article (SE1019), which provides a broad overview of the many issue related to the transition to ICD-10. 

Another resource for physicians is the periodic free ICD-10 educational conference calls conducted by CMS. In recent calls, Medicare agency staff outlined steps providers can take now to begin preparing for the 5010 update and ICD-10 implementation in recent provider conference calls. Highlights are below. 

The next CMS-sponsored call on ICD-10 will occur on September 13, 2010, from 12:00 p.m. – 1:30 p.m. Eastern time. This teleconference will focus on ICD-10 implementation issues. A question and answer session will follow the discussion. Specific agenda items and registration information will be available in August and posted on the CMS website. 

ASTRO will continue following this issue and update members as new information becomes available.