CMS and CDC/NCHS Discuss Possible Biannual ICD-10-CM/PCS Code Implementation Dates

The ICD-10 Coordination and Maintenance (C&M) Committee, co-chaired by the Centers for Medicare and Medicaid Services (CMS) and the National Center for Health Statistics/Centers for Disease Control and Prevention (CDC/NCHS), met March 9-10 this year to discuss proposals for new or modified ICD-10-CM and ICD-10-PCS codes. All ICD-10-PCS code proposals presented at the March ICD-10 C&M Committee would, if approved, go into effect on October 1, 2021. All but one of the ICD-10-CM code proposals were presented for consideration of an October 1, 2022 implementation date. The exception is discussed below.

CMS and CDC/NCHS announced their consideration of an April 1 implementation date for ICD-10-CM/PCS code updates, in addition to the current October 1 annual update. If an April 1 code implementation is adopted, requesters of new or modified codes would indicate whether they are submitting their code request for consideration of an April 1 or October 1 implementation date. The ICD-10 C&M Committee would make efforts to accommodate the requested implementation date for each request submitted, however, the committee would determine which requests would be presented for consideration of an April 1 vs. October 1 implementation date. The first April 1 code update would be April 1, 2022.

The current established process would be used to implement an April 1 code update, which would include presenting proposals for April 1 consideration at the September ICD-10 C&M Committee meeting, requesting public comments, reviewing public comments, finalizing codes, and announcing the new codes, consistent with the new Grouper release information. The code update process for an April 1 implementation date would also involve the release of new code files, coding guidelines, and coding advice on the use and reporting of new codes through the American Hospital Association’s Coding Clinic for ICD-10-CM/PCS publication.

CMS would assign the codes approved for an April 1 update to MS-DRGs using its established process for Grouper assignments for new diagnosis and procedure codes. CMS would list the codes approved for an April 1 update in the annual hospital inpatient prospective payment system (IPPS) proposed rule, along with their proposed Grouper assignments beginning October 1 of the next fiscal year.

According to a sample timeline provided by CMS and CDC/NCHS, on February 1, 2022, ICD-10 MS-DRG Grouper software and related materials would be posted on CMS’ website, and the April 1 code update files and updates to the ICD-10-CM and ICD-10-PCS official coding guidelines would be posted on the CMS and CDC/NCHS websites.

CMS and CDC/NCHS are seeking input on the possible adoption of an April 1 code implementation date, including how it may impact organizations’ business processes and what factors the ICD-10 C&M Committee should consider when determining which requests should be considered for either an April 1 or October 1 implementation date. Comments on this topic should be submitted by May 7 to CMS at ICDProcedureCodeRequest@cms.hhs.gov and CDC/NCHS at nchsicd10cm@cdc.gov.

During this meeting CMS also discussed the disposition of ICD-10-PCS Section X codes after they had been in effect for three years. CMS had previously stated that they would propose one of these three options:

1. Leave the code in Section X (e.g., procedure codes related to the administration of a specific medication)
2. Reassign the code to the Med/Surg or other section of ICD-10-PCS and delete from Section X (e.g., new technology add-on payment has expired, data analysis and clinical review justifies incorporating this technology/procedure into the main Med/Surg section)
3. Delete the Section X code (e.g., the procedure is not reported as anticipated in the data, therefore the absence of a unique code for this technology/procedure in the classification has minimal impact)

Based on public input (including recommendations from AHIMA), CMS proposed a fourth option for consideration at the March C&M meeting:

4. Create a new code in Med/Surg or other section of ICD-10-PCS and delete the code from Section X (e.g., new technology add-on payment has expired, data analysis and clinical review justify uniquely identifying the technology in the Med/Surg section).

The CDC/NCHS proposed adding a new ICD-10-CM code for “post COVID-19 condition” that would become effective on October 1, 2021. The World Health Organization has already added a code in ICD-10. If there is a description of a sequela of COVID-19, a residual condition following COVID-19, or a post COVID-19 condition documented in the medical record, then the new proposed code would be used. If the patient has a history of COVID-19, without a current related condition, then it would be appropriate to assign code Z86.16, Personal history of COVID-19. If there is a current infection or recurrent infection with COVID-19, then code U07.1, COVID-19, should be assigned. If the medical record documentation is not clear as to whether there is an active COVID-19 infection, symptom, or condition due to a previous COVID-19 infection, or personal history of COVID-19, it would be appropriate to query the provider.

An expansion of ICD-10-CM codes describing social determinants of health (SDOH) was proposed by the Gravity Project. The Gravity Project is a national, public, consensus-based community charged with developing data elements and data standards for SDOH by leveraging the insights of subject matter experts and key stakeholders across the medical and social care community (patients, providers, payers, community-based organizations, vendors, and government). According to the code proposal, growing literature over the last decade has clarified and further identified the SDOH and the impact on health costs. Advances have been made to collectively gain insight into social risks and social interventions, yet the terminology used to represent these concepts lags behind.

Although the expected implementation date for the SDOH code proposal—if the new codes are approved—was proposed as October 1, 2022, AHIMA recommended that CDC/NCHS consider implementing these codes on October 1, 2021. In AHIMA's comment letter, we noted that the recognition of the impact of SDOH on health outcomes and risks, as well as interest in leveraging SDOH data to improve health outcomes and address health inequities, have continued to grow. The COVID-19 pandemic has further highlighted the importance of SDOH and accelerated the demand for collection of better SDOH data. AHIMA’s policy statement on SDOH supports AHIMA’s recommendation for expedited implementation of new SDOH ICD-10-CM codes. Per this policy statement, AHIMA supports the use of public policy to encourage the collection, access, sharing, and use of SDOH to enrich clinical decision-making and improve health outcomes, public health, and health inequities in ways that are culturally respectful. The policy statement notes that, to improve the collection, access, sharing, and use of SDOH data, AHIMA believes that public policy must establish global standards to promote the capture, use, maintenance, and sharing of SDOH data. Identification of existing medical coding vocabulary gaps is needed to document and capture standardized SDOH data elements, and policy must ensure that the processes for updating vocabularies and code sets routinely includes consideration of SDOH data needs.

Comments may be sent to CDC/NCHS on the ICD-10-CM code proposals (except for post COVID-19 condition) and proposed ICD-10-CM Addenda changes presented at the March C&M meeting until May 10. Comments on the proposed ICD-10-CM code changes should be sent to nchsicd10cm@cdc.gov. The deadline has lapsed for comments on the ICD-10-PCS proposals and the ICD-10-CM proposal for post COVID-19 condition.

Materials from the March C&M meeting, including proposal packets, recording, presentations, and Q&As, can be accessed at the links below:

• ICD-10-PCS C&M materials
• ICD-10-CM C&M materials

Sue Bowman (sue.bowman@ahima.org) is senior director, coding policy and compliance, policy and government affairs at AHIMA.