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ICD-10 Code Set to Replace ICD-9

ICD-10 Delay
On April 1, 2014, the President signed into law the Protecting Access to Medicare Act of 2014, which had passed the House on March 27 and the Senate on March 31. While the primary focus of the law is to provide a temporary patch to the Sustainable Growth Rate (SGR) for physician payment, Section 212 establishes a delay for the implementation of ICD-10. The language states that the Secretary of Health and Human Services (HHS) may not adopt the ICD-10 code sets prior to October 1, 2015.

While the AMA has advocated against ICD-10, it was not the source of the inclusion of a delay in this law. The AMA spoke out against the proposed legislation before it was passed due do its opposition to a temporary fix for the SGR. Dr. Hoven, AMA President, stated, “The AMA and other physician organizations strongly agree that while a delay in ICD-10 implementation provides welcomed temporary relief, it does not offset the continued harm caused by keeping the SGR formula on life support and further delaying badly needed Medicare physician payment reforms. The AMA remains committed to relieving physicians of the crushing administrative burdens and practice disruptions that are anticipated during the scheduled transition to ICD-10.”

At this time, the industry is awaiting further direction from the Centers for Medicare & Medicaid Services (CMS), the agency that oversees the implementation of HIPAA code sets, on a new date for the implementation of ICD-10 or the process through which the new date will be established.

AMA Releases Updated ICD-10 Physician Cost Impact Report
On Wednesday, February 12, the AMA published a report by Nachimson Associates updating cost data for physicians to comply with ICD-10. The study updates costs from an earlier 2008 study the highlights of which are discussed in a press release. The report found that small practices can expect to spend anywhere between $56,639 to $226,105. The new estimates factor in the costs associated with purchasing new software to accommodate the new codes. Issued in conjunction with the report and press release was a letter to Secretary Sebelius reiterating the AMA’s request that ICD-10 be repealed because it is a costly, unfunded mandate for practicing physicians. While the AMA continues to seek a repeal of ICD-10, it nonetheless remains a federal mandate and physicians are urged to prepare for the October 1, 2013 compliance deadline.


The differences between ICD-9 and ICD-10 are significant and physicians and practice management staff need to start educating themselves now about this major change so that they will be able to meet the October 1, 2014 compliance deadline.

ICD-10-CM codes are the ones designated for use in documenting diagnoses. They are 3-7 characters in length and total 68,000, while ICD-9-CM diagnosis codes are 3-5 digits in length and number over 14,000. The ICD-10-PCS are the procedure codes and they are alphanumeric, 7 characters in length, and total approximately 87,000, while ICD-9-CM procedure codes are only 3-4 numbers in length and total approximately 4,000 codes.

Moving to ICD-10 is expected to impact all physicians. Due to the increased number of codes, the change in the number of characters per code, and increased code specificity, this transition will require significant planning, training, software/system upgrades/replacements, as well as other necessary investments.

Before the ICD-10 codes can be used however, physicians and others in the health care community had to transition to use of the new version of HIPAA transaction standards known as 5010 by January 1, 2012, as the current version, 4010, does not accommodate use of the ICD-10 codes.

The Department of Health and Human Services announced a one year delay of ICD-10 implementation which is now scheduled for October 1, 2014. AMA Board Chair Steven J. Stack, MD commented, "The AMA appreciates the administration's decision to provide a one year delay in response to AMA advocacy, but we have urged CMS to do more to reduce the regulatory burdens on physician practices so physicians can spend more time with patients."

"This is not the final action on this issue. In the rule, the administration stated its commitment to ‘engage stakeholders on a wide variety of ICD-10 implementation issues, including reduction of burden on physician practices'."

The AMA looks forward to working with the Administration to address physician concerns with ICD-10 and the multiple reporting programs and burdens associated with them, in greater depth.

Medicare Testing

As a result of persistent AMA advocacy, the Centers for Medicare and Medicaid Services (CMS) recently announced that they will conduct end-to-end testing with a limited number of health care providers of varying sizes and types including physicians. Initially, CMS said Medicare had no plans to do any testing whatsoever on ICD-10. Last year, amidst an outcry for testing, CMS announced Medicare would do some very limited testing that essentially only alerts physicians to whether or not their contractor had received their claim. CMS is calling this limited testing “acknowledgements testing.” End-to-end testing, however, is far more extensive which will cover submission of test claims to CMS with ICD-10 codes and the physician’s receipt of a Remittance Advice (RA) that explains the adjudication of the claims. The goal of this testing is to demonstrate that:

  • Physicians or their claims submitters are able to successfully submit claims containing ICD-10 codes to the Medicare FFS claims systems;
  • CMS software changes made to support ICD-10 result in appropriately adjudicated claims (based on the pricing data used for testing purposes); and
  • Accurate RAs are produced

CMS will be announcing a process for physicians and others to sign up to be included in the end-to-end testing. CMS also announced that physicians interested in conducting “acknowledgements testing” will be able to do so through the compliance deadline of October 1 by contacting their contractor. More information on testing can be found in this MLNMatters article.

ICD-9 and ICD-10 Code Freeze

Partial Code Freeze Prior to ICD-10 Implementation
At the ICD-9-CM Coordination & Maintenance Committee Meeting on Sept. 15, 2010, it was announced that the committee had finalized the decision to implement a partial freeze for both ICD-9-CM codes and ICD-10-CM and ICD-10-PCS codes prior to the compliance date. When the compliance date was delayed until Oct. 1, 2014, the dates of the partial freeze were adjusted.The partial freeze will be implemented as follows:

  • The last regular annual update to both ICD-9 and ICD-10 code sets was made on October 1, 2011.
  • On October 1, 2012 and October 1, 2013, there will be only limited code updates to both ICD-9-CM and ICD-10 code sets to capture new technology and new diseases.
  • There will be no updates to ICD-9-CM on October 1, 2014 as the system will no longer be a HIPAA standard. Only limited updates will be made to ICD-10 for new technology and new diseases
  • On Oct. 1, 2015, regular updates to ICD-10 will begin.

The ICD-9 Coordination & Maintenance Committee will continue to meet twice a year during the freeze. At these meetings the public will be allowed to comment on whether or not requests for new diagnosis and procedure codes should be created based on the need to capture new technology or disease. Any code requests that do not meet the criteria will be evaluated for implementation within ICD-10 on or after Oct. 1, 2015, once the partial freeze is ended.

View the Sept. 15-16, 2010 meeting transcript. Discussion begins on page 4 of the 78-page proceeding.


What is “ICD-10”?
“ICD-10” is the abbreviated way to refer to the International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM) and International Classification of Diseases, Tenth Revision, Procedure Coding System (ICD-10-PCS).

Explain the difference between ICD-10-CM and ICD-10-PCS.
ICD-10-CM is the diagnosis code set that will be replacing ICD-9-CM Volumes 1 and 2. ICD-10-CM will be used to report diagnoses in all clinical settings. ICD-10-PCS is the procedure code set that will be replacing ICD-9-CM Volume 3. ICD-10-PCS will be used to report hospital inpatient procedures only.

Will ICD-10-PCS replace CPT®?
No. ICD-10-PCS will be used to report hospital inpatient procedures only. The Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) will continue to be used to report services and procedures in outpatient and office settings.

Do I have to upgrade to ICD-10?
Yes. The conversion to ICD-10 is a HIPAA code set requirement. Providers, including physicians, are HIPAA “covered entities”, which means that you must comply with the HIPAA requirements.

Who else has to upgrade to ICD-10?
Health care clearinghouses and payers are also HIPAA covered entities, so they are required to convert to ICD-10 as well.

I thought HIPAA code set standards only applied to the HIPAA electronic transactions. What if I don’t use the HIPAA electronic transactions?
It is correct that HIPAA code set requirements apply only to the HIPAA electronic transactions. But, it would be much too burdensome on the industry to use ICD-10 in electronic transactions and ICD-9 in manual transactions. Payers are expected to require ICD-10 codes be used in other transactions, such as on paper, through a dedicated fax machine, or via the phone.

Why is ICD-9 being replaced?
The ICD-9 code set is over 30 years old and has become outdated. It is no longer considered usable for today’s treatment, reporting, and payment processes. It does not reflect advances in medical technology and knowledge. In addition, the format limits the ability to expand the code set and add new codes.

The ICD-10 code set reflects advances in medicine and uses current medical terminology. The code format is expanded, which means that it has the ability to include greater detail within the code. The greater detail means that the code can provide more specific information about the diagnosis. The ICD-10 code set is also more flexible for expansion and including new technologies and diagnoses. The change, however, is expected to be disruptive for physicians during the transition and you are urged to begin preparing now.

When do I have to convert to ICD-10?
All services and discharges on or after October 1, 2014 must be coded using the ICD-10 code set. The necessary system and workflow changes need to be in place by the compliance date in order for you to send and receive the ICD-10 codes.

What if I’m not ready by the compliance deadline?
Any ICD-9 codes used in transactions for services or discharges on or after October 1, 2014 will be rejected as non-compliant and the transactions will not be processed. You will have disruptions in your transactions being processed and receipt of your payments. Physicians are urged to set up a line of credit to mitigate any cash flow interruptions that may occur.

Deadlines for other HIPAA requirements have been delayed. Will the compliance date for ICD-10 be delayed?
Do not expect there to be a delay in the ICD-10 compliance deadline. The Centers for Medicare & Medicaid Services (CMS) is responsible for oversight of compliance with the HIPAA code set requirements. CMS has made it clear that there will be no extension of the deadline for ICD-10. Work within Medicare to upgrade to the ICD-10 transactions is on target and they expect to be ready on time.

What do I need to do now to prepare for the conversion to ICD-10?
There are several steps you need to take to prepare for the conversion to ICD-10.

  • Begin by talking to your practice management or software vendor. Ask if the necessary software updates will be installed with your upgrades for the Version 005010 (5010) HIPAA transactions. If you do not use the HIPAA transactions, determine when they will have your software updates available and when they will be installed in your system. Your conversion to ICD-10 will be heavily dependent on when your vendor has the upgrades completed and when they can be installed in your system.
  • Talk to your clearinghouses, billing service, and payers. Determine when they will have their ICD-10 upgrades completed and when you can begin testing with them.
  • Identify the changes that you need to make in your practice to convert to the ICD-10 code set. For example, your diagnosis coding tools, “super bills”, public health reporting tools, etc.
  • Identify staff training needs and complete the necessary training.
  • Conduct internal testing to make sure you can generate transactions you send with the ICD-10 codes.
  • Conduct external testing with your clearinghouses and payers to make sure you can send and receive transactions with the ICD-10 codes.

ICD-10 Implementation Planning

AMA offers planning tools to increase ICD-10 understanding and readiness.

  • ICD-10 Action Plan: Your 12-Step Transition Plan for ICD-10
    Practice Tool written by the AMA CPT Medical Informatics Department Implementation of ICD-10-CM is set for October 1, 2014. But transitioning to ICD-10 needs to begin now. This ICD-10 practice tool offers 12 critical steps along with tables and forms to help you make a smooth transition. A short glossary and list of AMA ICD-10 resources are also included. Release date: September 4, 2012.
  • What You Need to Know for the Upcoming Transition to ICD-10-CM
    White Paper written by the AMA CPT Medical Informatics Department
    ICD-10 represents a significant improvement over ICD-9, but structural differences make converting complex. Learn more about this as well as code set differences, reasons for the conversion, crosswalking concerns, and transition tips.
    Release date: June 1, 2012.

AMA Advocacy on ICD-10

AMA testimony to National Committee on Vital and Health Statistics Subcommittee on Standards on achieving a successful transition, February 19, 2014

Letter to HHS on Updated Cost Impact Data and Request for Medicare to Test and Fund Advance Payments, February 12, 2014

Letter to HHS on Penalty Programs and ICD-10, June 14, 2013

Letter to Sen. Tom Coburn supporting S. 972, May 21, 2013

Letter to Rep. Poe supporting H.R. 1701, April 26, 2013

CMS response to December 2012 letter from Medicine

Sign-on letter to CMS re: ICD-10 delay (RES 209-I-12), December 20, 2012

Letter from AMA to CMS on May 10, 2012 in response to proposed rule to extend compliance deadline.

Letter and attachment from AMA to HHS on February 2, 2012

Letter and attachment from AMA to Senator Harkin, January 17, 2012

AMA testimony to the National Committee on Vital and Health Statistics Subcommittee on standards regarding the industry implementation of updated and new HIPAA standards and code sets, June 17, 2011

Letter from AMA and medical specialty societies to HHS, October 28, 2010

AMA testimony to the National Committee on Vital and Health Statistics’ Subcommittee on standards regarding the planning and implementation of the updated HIPAA transactions and code sets, December 10, 2009

Letter from Representative Velazquez to HHS, November 19, 2008

Letter to CMS on ICD-10 proposed rule, October 21, 2008

Letter to the Office of Management and Budget, July 24, 2008

Letter to HHS, April 1, 2007

Letter to Senate Majority Leader, September 19, 2006

Letter to HHS National Committee on Vital and Health Statistics, September 23, 2003

AMA Educational Resources


  • New Article on Preparing for ICD-10
    "The Current State of ICD-10 & Preparing for It" was published in the November/December 2013 Missouri Medicine Journal. The article provides an overview of ICD-10, the AMA’s advocacy against it, and information on how to prepare for it. The article is posted on here with the permission of the Missouri State Medical Association.
  • AMA White Paper on ICD-10, EHRs, and Administrative Simplification
    The AMA has published a white paper that discusses the promised benefits of ICD-10, EHRs, and administrative simplification. The paper describes the initial regulations and anticipated gains from them. Recommendations on what practices can do to achieve these benefits are also provided.

Tip Sheet Series

5010 and ICD-10: What They Are and How to Prepare for Them Watch this archived webinar that provides an overview on implementing the HIPAA 5010 transactions and ICD-10.

ICD-10 Checklist

ICD-10 Project Plan Template - Steps to Take to Implement ICD-10

Preparing for the Conversion from ICD-9 to ICD-10: What You Need to Be Doing Today

ICD-10 Fact Sheet Series

American Medical News & Wire articles
The following resources are available from the AMA Store for a cost:
  • AMA Training & Events – Choose from a variety of live event training, online modular training or pre-recorded webinar options to aid in your understanding of ICD-10
  • AMA Print Resources – AMA publishes ICD-10 codebook as well as supplementary ICD-10 titles that cover topics like documentation, anatomy and physiology, mapping, and correct coding
  • AMA Data Files – Begin testing your electronic systems now with an ICD-10 Data File created by the AMA

Additional Resources