ICD-10 Compliance Deadline is October 1, 2014—Philadelphia Office of CMS to Offer Webinars to Ease Transition

February 2, 2014 | By Lawrence J. Tabas

ICD-9 diagnosis and inpatient procedure codes will make way for ICD-10 codes starting October 1, 2014. Health care entities and providers need to be ready to make the switch if they want to receive reimbursement for claims.

According the Centers for Medicare & Medicaid Services (“CMS”), ICD-10 (which stands for the International Classification for Diseases Tenth Edition) is replacing the Ninth Edition because ICD-9 produces only limited data about patients’ medical conditions, has outdated terms, and is inconsistent with current medical practice. ICD-10 codes, which will be longer and alphanumeric, will supposedly allow for greater specificity in coding, be reflective of new diagnoses and procedures, and account for innovations in the health care field. 

Every health care entity or provider subject to the Health Insurance Portability and Accountability Act (“HIPAA”) will need to make the transition from the old codes to the new codes. If an entity or provider fails to make the change, any claims made using the ICD-9 codes cannot be paid.

In preparation for October, health care entities and providers should start strategizing now on how best to implement the ICD-10 codes. CMS has offered some helpful guidance through a fact sheet and FAQs on how providers can prepare for the change. CMS suggests that providers:

  • Analyze the impact the new codes will have on the provider’s organization. Providers should determine the effect of the new codes on the organization, clinical documentation, and electronic health records.
  • Develop a strategy for implementing the new codes. This breadth of the strategy will depend on the size of the provider’s organization, but all providers should consider establishing a transition team or point person, creating an implementation plan, and carving out an implementation budget.
  • Communicate with those involved in the transition. Organizations should make sure there are open lines of communication between the people responsible for facilitating the transition and also in making sure everyone in the organization understands their role with regard to the new codes (this could include billing and information technology staff). Organizations and providers should also coordinate with payers to ease the transition.

Even if providers are prepared to make the change tomorrow, providers should keep in mind that ICD-9 codes will need to be used until the October 1, 2014 compliance deadline. In order to facilitate the change, the Philadelphia Regional Office of CMS is offering a webinar in February.  For more information about the webinar, click here.

The CMS Fact Sheet is available here.

The CMS FAQs are available here.

The Health Law Gurus™ will continue to follow the transition to ICD-10 coding. Please share your thoughts and experiences regarding ICD-10 with us and our readers in the comments section below.

About the Authors

Lawrence J. Tabas


Lawrence is the Chair for Obermayer’s Health Care Law Department and Election Law Practice Group. Lawrence’s Health Care Law legal experience includes the representation of Pennsylvania County governments in Behavioral Health Managed...

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