Transitioning from ICD-9 to ICD-10

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In 1948 the World Health Organization published the first edition of the International Classification of Diseases (ICD) and had gained international recognition by 1977 and the United States National Center for Health Statistics modified the ICD-9 code set for use in our nation. On April 1, 1989, by an act of Congress, ICD-9 codes became the basis for Medicare reimbursement (1).

Uses of ICD

In 1996, the Health Insurance Portability and Accountability Act established the requirement that ICD-9 codes be used for nearly every medical claim processed in the United States. The World Health Organization periodically revises the ICD code set and the current ICD-10 is used in about 110 countries. The United States is the last major industrialized nation to make the switch to ICD-10(2).

Changes and examples of differences

The transition to ICD-10 is occurring because ICD-9 produces limited data about patients’ medical conditions and hospital inpatient procedures. ICD-9 is 30 years old, has outdated terms, and is inconsistent with current medical practice. Also, the structure of ICD-9 limits the number of new codes that can be created, and many ICD-9 categories are full(3). For example, asthma is classified under the ICD-9 coding system as 493.0 (extrinsic asthma), 493.1 (intrinsic asthma), and 493.2 (chronic obstructive asthma), which only details the type of obstructive asthma, whereas the ICD-10 classifies asthma as mild intermittent (J45.2), mild persistent (J45.3), moderate persistent (J45.4), and severe persistent (J45.5) each with a further number corresponding to current conditions (for example J45.51 is severe persistent asthma with acute exacerbation), which is a much more useful classification clinically.

Mandate to change

On 1/16/2009 Department of Health and Human Services (HHS) published a final rule mandating that healthcare organizations implement ICD-10-CM/PCS by Oct 1, 2013 (4), although this date may be delayed (5).

Penalty for failure to change

Everyone covered by the HIPAA must transition to ICD-10 on October 1, 2013 (or possibly a later date) including providers and payers who do not deal with Medicare claims. Claims for all services and hospital inpatient procedures provided on or after October 1, 2013, must use ICD-10 diagnosis and inpatient procedure codes. (This does not apply to CPT coding for outpatient procedures.) Claims that do not use ICD-10 diagnosis and inpatient procedure codes cannot be processed (and therefore will not receive reimbursement)(6).

Strategies for Change

The American Health Information Management Association (AHIMA) has detailed a 'top ten list' of procedures to put into place to ensure a smooth transition from ICD-9 to ICD-10. The differences between the two databases could not be more different than they are and will require a significant amount of resources in personnel and time. In fact, the time-line for successful transition has already begun if the original deadline date of October 1, 2013 remains in place, as outlined in their list as follows:

ICD-10 Top 10 List from AHIMA (7)

1. Ensure Organizational Awareness

  a. Provide organization-wide ICD-10 awareness education to key stakeholders
  b. Include senior management, information technology personnel, clinical department managers,medical staff
  c. HIM managers and coding professionals should become familiar with the format, basic structure and fundamentals of ICD-10-CM/PCS
  d. Establish and execute a communication plan for the entire health care organization

2. Establish Executive Leadership

  a. Develop multi-disciplinary steering committee to develop implementation strategy and oversee implementation process
  b. Formulate transition strategies and identify goals
  c. Identify key stakeholders requiring awareness education and ensure education provided
  d. Identify key tasks and objectives and assign to appropriate departments for follow-up
  e. Prioritize concurrent projects both related and unrelated to ICD-10-CM/PCS to ensure timelines are met

3. Perform Impact Assessment

  a. Identify range of impact on every department
  b. Analyze impact on operational processes
  c. Assess impact on documentation processes and work flow
  d. Identify impacted internal and external reporting
  e. Assess the detail in clinical documentation to determine whether it is adequate to support ICD-10-CM/PCS

4. Conduct Systems Inventory

  a. Inventory all databases and systems applications (including interfaces) using ICD-9-CM codes
  b. Perform detailed analysis of systems changes needed
  c. Request documentation from vendors on their plans to prepare for the transition

5. Complete Gap Analysis

  a. Perform GAP analysis on the areas of impact
  b. Develop a strategic organizational approach
  c. Identify and rank risks and identify any contingency plans

6. Establish Internal Timeline

  a. Develop internal implementation timeline
  b. Specify resources required to complete identified tasks
  c. Monitor timeline and update as needed

7. Determine Plan for Training

  a. Perform detailed assessment of current-day coding staff knowledge
  b. Identify the specific groups who need training (role-based)
  c. Identify at what level training needs to be provided to all categories of users
  d. Determine method and timeline for training

8. Prepare Multi-year ICD-10 Implementation Budget

  a. Perform budget assessment and procurement of needed funds to staff the transition project
  b. In this project consider:
     i. System, hardware, maintenance fee upgrades
     ii. Training
     iii. Outsourcing or consultant fees
     iv. Temporary staffing needs
     v. Data conversion
     vi. Report redesign and reprinting paper forms
     vii. Additional tools or resources needed
     viii. Systems testing

9. Manage Contractual Changes

  a. Review vendor and payer contracts early and collaborate with external parties to determine modifications
  b. Identify any additional fees from vendors

10. Correlate Continued Organizational Management of 5010 Implementation Processes Planning (required January 1, 2012)

  a. 5010 implementation and ICD-10 implementation are NOT sequential projects, they be concurrent projects
  b. Begin external testing of 5010 by January 1, 2011

The Healthcare Information Management Systems Society provides a comprehensive resource regarding information related to ICD-10(8).


1. The Value of ICD-10. (n.d.). Retrieved March 5, 2012, from HIMSS website:

2. ibid

3. The ICD-10 Transition: An Introduction. (2010, April). Retrieved March 5, 2012, from Centers for Medicare and Medicaid Services website:

4. HHS Releases Final ICD-10 Code Sets and Updated Electronic Transaction Standards Rules. (2009, January 15). Retrieved March 5, 2012, from Dept of Health and Human Services website:

5. HHS Announces Intent to Delay ICD-10 Compliance Date. (2012, February 16). Retrieved March 5, 2012, from US Dept of Health and Human Services website:

6. FAQs: ICD-10 Transition Basics. (2011, July). Retrieved March 5, 2012, from Centers for Medicare and Medicaid Services website:

7. American Health Information Management Association. ICD-10-CM/PCS Preparation Checklist at

8. HIMSS ICD-10 Playbook. (n.d.). Retrieved March 6, 2012, from Healthcare Information Management Systems Society website:

Submitted by Eric M. Perry