Partial Code Freeze Will Remain Through ICD-10 Delay

The possible one-year delay of ICD-10 compliance will also push back scheduled ICD-10 coding updates while maintaining the partial ICD-9 coding freeze currently in place.

At Monday’s ICD-10 Summit session discussing the Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention’s (CDC) ICD-10 preparation plans, CMS’ senior technical advisor Pat Brooks, RHIA, said that adding more codes to ICD-9 or ICD-10 would only complicate current coding efforts.

After the last regular coding update in October 2011, CMS instituted a partial code freeze that only allows code updates for new technology or diseases. That freeze was to be lifted in October 1, 2014—one year after the original ICD-10 implementation deadline. Once the delay was announced in February, many industry representatives asked CMS what would happen to the code freeze, Brooks said.

“We will extend the partial freeze through the delay of ICD-10,” Brooks said.

The first regular update to ICD-10 would be one year after the implementation deadline, or October 1, 2015, if the HHS proposed implementation date of October 1, 2014, is instituted after a rulemaking process.

The plethora of CMS resources that can be used to aid the ICD-10 implementation was also discussed at the session. ICD-10-CM/PCS teleconferences, training aids, and General Equivalence Mappings (GEMs) are just a few of the resources healthcare stakeholders were encouraged to use in their transitions.

Recently, CMS has received an increase in questions about the GEMs, likely signaling many providers are in a position to start using the crosswalks at their own facilities. Instead of reading the entire GEM reference guide, Brooks suggested using the GEMs basic and technical FAQ fact sheets, both of which can be found on the CMS Webpage at

While the GEMs do enable the conversion of data from ICD-9 to ICD-10, Brooks reminded the audience they should only be used temporarily.

“GEMs are not a substitute for learning how to code,” she said.

In addition to GEM usage, another frequently asked question addressed was the number of duplicate codes that appear in both ICD-9 and ICD-10.While they have the same code name (not counting decimal points) the duplicates don’t mean the same thing. Several data users worried that the duplicate codes could affect and confuse implementation efforts.

Out of the thousands of ICD-9 and ICD-10 codes, only 39 codes are duplicates, Brooks said, with all the duplicates starting with “E.” This is a manageable number, and data analysts shouldn’t be concerned if they take the proper steps to mitigate the effects.

Providers and HIPAA-covered entities are not the only ones who have to convert to ICD-10. CMS had its own headaches to deal with regarding the conversion. Brooks described the recent conversion of MS-DRGs to ICD-10 MS-DRGs using the GEMs as “pretty much a nightmare.” The conversion, which will be subject to formal rulemaking before it becomes official, did not change the payment of the DRGs, just the code structure, she said. CMS has posted a “lessons learned” online paper about the MS-DRG conversion to aid those undertaking similar projects.

Brooks encouraged the audience members and the public at large to submit their comments on the proposed one-year delay—both positive and negative.

CDC Relies on HIM Pros to Help Convert

In the CDC portion of the session, CDC’s medical systems administrator Donna Pickett, MPH, RHIA, discussed how CDC aids in the development of new code sets.

The CDC’s National Center for Health Statistics (NCHS) developed and maintains ICD-10-CM as a replacement for ICD-9-CM diagnoses.

While the CDC uses coded data frequently in its various population health initiatives, it doesn’t have direct access to the medical records those codes are based on. This means they had to rely almost exclusively on the GEMs to convert their systems from ICD-9 to ICD-10, Pickett said. The CDC is one of several entities that, while not covered by HIPAA, must also transform their systems since they use ICD-9 data, she said.

Like a hospital, CDC also had to conduct an impact analysis that rooted out all the programs and areas that currently use ICD-9. They searched through 90 programs, and just like a hospital, Pickett explained, many program leaders at CDC were surprised at how integrated ICD-9 was in their system and the effort needed to convert to ICD-10. They found ICD-9 in data systems, applications, tools, data stores, tables, and even programming code. The CDC plans to add more HIM-based positions to help the organization transition to ICD-10.

“How do you take a non-HIM professional that has never heard of PCS and ask them to look at what the transition entails?” she said. “Next thing I get a phone call with a silent scream. We understand that silent scream.”

Their current staff can’t do it alone, Pickett emphasized, and many programs and departments do not have individuals with HIM expertise. That said, her team does expect to train some staff about the ICD-10 transition to build the skills that will allow them to manage and analyze incoming data.

“We are just at the tip of the iceberg in what programs are impacted,” she said. “But we are just now drilling down into those programs. Many weren’t fully aware of the impact.”


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