US Must Adopt and Implement ICD-10-CM and ICD-10-PCS: Immediate Action to Upgrade Medical Code Set Standards Needed

Approved July 2007

AHIMA’s Position

AHIMA calls upon the Department of Health and Human Services (HHS), Congress, and the healthcare industry to take immediate action to adopt and implement ICD-10-CM and ICD-10-PCSi classification code sets, rules and guidelines as replacements for ICD-9-CM. This action ensures more complete healthcare data collection that reflects a patient’s health as well as the nation’s healthcare delivery system as a whole.

The ICD-9-CM classification system used in the United States today does not meet current healthcare data needs and cannot support the transition to interoperable health data exchange in the US. The ICD-10-CM and ICD-10-PCS replacement standards have been available since the late 1990s, and the accompanying ASC-X12 and NCPDP transaction standards are available to transmit the vital data represented by the upgraded ICD-10- CM and ICD-10-PCS classification systems.

Therefore, we urge Health and Human Services and/or Congress to initiate either legislative or regulatory action that will reverse this trend of deteriorating health data. Immediate policy action will enable the healthcare industry to prepare for a smooth transition into a 21st century classification system no later than 2011.


  • Congress must pass legislation enabling adoption and implementation of the ICD-10-CM and ICD-10-PCS classification systems and the necessary ASC X12 Version 5010 and NCPDP Version D.O transaction standards updates so that the ICD-10-based codes will be in effect no later than October 1, 2011.
  • Alternatively, HHS must initiate the necessary regulatory processes for the adoption and implementation of these same classification and transaction standards to accomplish a final conversion by October 1, 2011.
  • Healthcare industry information technology (HIT) systems vendors should commit to building the necessary HIT software that will allow for easy conversions to the ICD-10 based codes from this point forward. The standards and structures are known and published; such a commitment would lessen the cost of any further delay in the inevitable adoption and implementation of the ICD-10 standards.
  • Providers, health plans, payers, and professions throughout the healthcare industry should examine and recognize the need for and make the effort to transform the classifications use for reporting on US disease and inpatient procedures to reflect international, 21st century coding standards and 21st century medicine. It is critical for US citizens to benefit from complete, accurate, and standard healthcare data and information represented in these classifications systems.

Why AHIMA Supports the Position

  • Accurate detailed healthcare information is crucial for:
    • Healthcare clinical decision-making and communication between other clinicians and the patient
    • Health research and treatment development
    • Public health monitoring and biosurveillance as well as international health data exchange
    • Quality measurement for safety, and efficacy of medical care
    • Healthcare management and policy decision-making including actuarial premium setting, cost analysis, and service reimbursement (such as Medicare) based on accurate and detailed disease, medical procedure, and severity data.
  • The need to update the then-20-year-old ICD-9 based code set was recognized both here and around the world in the early 1990s. That’s when steps were taken to develop a replacement. The international conversion to ICD-10 based classifications began in the mid-1990s. Currently, the US is the only industrialized nation not using an ICD-10 based classification system for morbidity purposes. Simply put, we’re trying to describe early 21st century medicine with mid-1970s classification. In doing so we ignore the increased medical knowledge and technology gained over 30 years.
  • The current US disease classification is incompatible with the structure of the ICD-10-based system, which was revised by the World Health Organization (WHO) to permit flexibility, expansion, and future upgrades. The US, using the ICD-9-CM, is presently rationing its codes and is difficult to adopt new codes to describe pandemic flu and other new disease outbreaks. This also means that codes cannot be adequately or appropriately assigned to describe improved knowledge of medicine and disease or detail 21st century medical procedures and technology. As the US waits to convert to the contemporary ICD-10 classification system, the cost of converting continues to increase as the current push for adoption of HIT in all sectors of the industry accelerates.
  • Failure of the ICD-9-CM to accurately describe contemporary diseases, groundbreaking medical procedures, or landmark technology raises concerns for myriad programs that rely on ICD-9-CM codes for information. This is especially true for data extracted during insurance claims processing. The limitation of ICD-9-CM codes to provide detailed data also causes data recipients to request additional information from providers, which generally requires the increasingly expensive process of paper transactions, i.e., information copied from (or direct copies of) the individual’s health record. The process also limits the ability to use the information unless “re-keyed” again, thus adding costs to the processing of information.
  • The standard electronic health record (EHR) and health information exchange, being championed by the federal government and the industry, relies on the use of terminology systems for the collection and storage of (primary) data. Classification systems such as ICD-10 have been built to convert the data in these terminology systems to secondary data for a variety of uses. The outdated ICD-9-CM codes do not efficiently or effectively represent the knowledge and information contained in the modern EHR. This limits the return on investment (from increased quality, efficiencies and use of secondary data) and the interoperability of data.
  • Industry critics of upgrading the US classification systems to international-level standards have repeatedly cited the need for an ample conversion period. Legislation in Congress provides for such an implementation period, but no progress has been toward achieving final adoption and beginning the necessary steps for implementation. The longer the US delays in implementing modern classifications and terminologies, the more information systems and software programs will need to be converted retroactively, resulting in higher conversion costs for hospitals, physicians and other healthcare entities.
  • The United States has been over-spending taxpayer dollars to maintain much-improved classification systems without taking advantage of their benefits. The US revisions for ICD-9-CM updating were initially completed in the late 1990s and the United States has been maintaining it since then-without using it. Crossover maps between ICD-9- CM and the ICD-10 classifications are in place. Revision of the X12 and NCPDP standards, necessary to identify the ICD-10 codes, has been achieved. The healthcare industry and its IT vendors are primed and capable to undertake a conversion. ICD-10-CM and ICD-10-PCS adoption must happen now to move US healthcare data into the 21st century.

For more information on ICD-10-CM and ICD-10-PCS and the need to convert to these 21st century classification systems as soon as possible, go to

i ICD stands for the International Classification of Diseases. 9 stands for the 9th revision and 10 for the 10th revision. CM stands for Clinical Modification (a US version of ICD-9 or ICD-10) ICD-9 and ICD-10 were developed and copyrighted by the World Health Organization (WHO). The WHO no longer supports ICD-9. ICD-10-PCS is a procedural coding system designed by the Centers for Medicare and Medicaid to replace the current inpatient procedural coding system currently included as part of ICD-9- CM.

AHIMA is the premier association of health information management (HIM) professionals. AHIMA's 51,000 members are dedicated to the effective management of personal health information needed to deliver quality healthcare to the public. Founded in 1928 to improve the quality of medical records, AHIMA is committed to advancing the HIM profession in an increasingly electronic and global environment through leadership in advocacy, education, certification, and lifelong learning.