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ICD 10 For Safety Net Providers

The objective of this webpage is to act as a resource for safety net providers to learn more about the conversion of ICD-9 to ICD-10. The deadline set by the Centers for Medicare and Medicaid Services  in a Final Rule (PDF - 579 KB) to convert to using ICD-10 is October 1, 2014. However, prior to this date, all providers that electronically transmit data needed to convert from coding version 4010/4010A1 to version 5010 by June 30, 2012.  Version 5010 is required to accommodate ICD-10 codes  Failure to convert and transmit data using ICD-10 codes will compromise a provider’s ability to bill for reimbursement and will also affect other activities including qualifying for quality incentive programs. This webpage provides resources on the definition of ICD-9 and ICD-10, who needs to transition, and available resources to support the transition.

What is ICD-9 and Why Is It Being Phased Out?

ICD-9-CM is the current coding system used in the United States. ICD-9 has been in use for 30 years. Its original purpose was diagnostic and procedural coding for statistics and research. However, since 1983 ICD-9 has also been used to communicate information on health care services for reimbursement. The National Committee on Vital Health and Statistics (NCHVS)  identified the need to replace ICD-9 in 1993 (Click her for NCHVS's Recommendation Letter to the Secretary of HHS), noting that the system was rapidly becoming outdated.  The U.S. is currently the only industrialized nation not using ICD-10.

What is ICD-10?

ICD stands for the  International  Classification of Diseases exit disclaimer .  ICD is the standard diagnostic classification for all general epidemiological conditions and includes codes for both clinical use as well as many health management services. ICD codes are used to evaluate the general health of population groups and monitor the incidence and prevalence of diseases and other health problems in relation to other variables like age, race, and socioeconomics. ICD codes can also be used to track adherence to quality principles and guidelines. .  

Why is the U.S. Converting to ICD-10?

On January 16, 2009, the U.S. Department of Health and Human Services (HHS) released a final rule  mandating that everyone covered by the Health Insurance Portability and Accountability Act (HIPAA)  must implement ICD-10 for medical coding on October 1, 2014.   The transition to ICD-10 is occurring because it provides more detailed classification about patients’ medical conditions and hospital inpatient procedures than the current system, ICD-9. ICD-9 has been in use in the United States for the past 30 years old, employs some terms which are now outdated, and is no longer consistent with current medical practice. ICD-10 will expand the content, scope and purpose of the system; it is also anticipated to reduce coding errors following its implementation.

Why is it Critical That I Switch to ICD-10?

A medical coding system should be flexible enough to quickly incorporate emerging diagnoses and procedures and exact enough to identify diagnoses and procedures precisely . ICD-9 is neither of these. Migrating to ICD-10 will streamline health care reimbursement and quality, and will reduce the need for clarifying documentation. In short,  failure to use ICD-10 for claims will result in reimbursement delay and claims returns. ICD-10 codes must be used on all HIPAA transactions, including outpatient claims with dates of service, and inpatient claims with dates of discharge on and after October 1, 2014. Otherwise, your claims and other transactions may be rejected, and they will need to be resubmitted with the ICD-10 codes.

This change does not affect CPT coding for outpatient procedures.

Additionally, a 2003 study published by the American Health Information Management Association exit disclaimer (AHIMA)  indicated that providers find ICD-10 to be a superior coding system and recommended that it be implemented sooner rather than later.

ICD-10-CM                             

ICD-10-CM is intended for use in all US health care settings. Diagnosis coding under ICD-10-CM uses 3 to 7 digits instead of the 3 to 5 digits used with ICD-9-CM, but the format of the code sets is similar.  

ICD-10-PCS

ICD-10-PCS is intended for use in U.S. inpatient hospital settings only. ICD-10-PCS uses 7 alphanumeric digits instead of the 3 or 4 numeric digits used under ICD-9-CM procedure coding. Coding under ICD-10-PCS is much more specific and substantially different from ICD-9-CM procedure coding.

Who in the Safety Net Community needs to transition?

ICD-10 will affect diagnosis and inpatient procedure coding for everyone covered by HIPAA,  not just those who submit Medicare or Medicaid claims. Everyone covered by HIPAA who transmits electronic claims must also switch to Version 5010 transaction standards . The change to ICD-10 will not affect CPT (aka Current Procedural Terminology) coding for outpatient procedures.

How are Safety Net Providers Preparing for ICD-10?


Federally Qualified Health Centers and Rural Health Clinics: HRSA's Bureau of Primary Health Care (BPHC) has been raising awareness to the Health Center Controlled Network (HCCN) grantees for ICD-10/5010 readiness. Safety net providers in community health centers within the HCCNs have started creating strategies through their vendors and billing departments to prepare for the coding deadlines. BPHC has created ICD-10/5010 tip sheets and collaborated with CMS on webinars in order to inform project officers and their grantees of the guidelines and deadlines related to this mandate. Tools from the Primary Care Associations and National Association of Community Health Centers for ICD-10/5010 conversion have been utilized by community health centers to support transition, planning, and preparation. HCCN project officers are also charged with querying their grantees on their progress and technical assistance needs on ICD-10/5010, through semi-annual progress reports and encourage awareness in conversations with grantees.

Critical Access Hospitals (CAH): CAHs and Small Rural Hospitals are providing staff training on ICD-10.

Implementation and Training

The October 1, 2014 implementation date is not flexible. All HIPAA covered entities must implement the new code sets by October 1st, 2014. It is crucial that ICD-10 codes are used after this date; if they are not, filed claims may be rejected, leading to delays in reimbursement.   An early start and a planned approach are essential in order to minimize and spread out costs and effort. The 2003 AHIMA study exit disclaimer  mentioned above recommended training start 3 months before implementation, if not earlier.  It is estimated that experienced inpatient coders will require 50 hours of additional training to code in ICD-10 (outpatient coders are expected to need 10 hours of additional training).

About the Version 5010 Transition on June 30, 2012

CMS has mandated that on June 30, 2012, standards for electronic health care transactions change from Version 4010/4010A1 to Version 5010. These electronic health care transactions include functions like claims, eligibility inquiries, and remittance advices.  Unlike the current Version 4010/4010A1, Version 5010 accommodates the ICD-10 codes, and must be in place first before the changeover to ICD-10. The Version 5010 change occurs well before the ICD-10 implementation date to allow adequate Version 5010 testing and implementation time.

If providers do not transmit electronic health transactions using Version 5010 as of June 30, 2012, delays in claim reimbursement may result. If health plans cannot accept Version 5010 transactions from providers, they may experience a large increase in provider customer service inquiries affecting their operations. Please see CMS’s website for more information on 5010 testing and information.

General Resources on ICD-10