Note to Congress: Do Not Delay ICD-10 Coding System

On December 5, 2014, the American Hospital Association (AHA) and seven other organizations representing over 5,000 hospitals wrote a letter urging Congress to implement the ICD-10 diagnosis coding system on the recently announced October 1, 2015, compliance date. The groups assert that prior implementation delays “have been disruptive and costly for hospitals and health systems, as well as to health care delivery innovation, payment reform, public health, and health care payment.”

Final Rule

After several delays, HHS issued a Final rule (79 FR 45128) requiring health care providers and other entities covered by the Health Insurance Portability and Accountability Act (HIPAA) (P.L. 104-191) to begin using International Classification of Diseases, Tenth Revision (ICD-10) diagnosis and procedure codes on Medicare and other health care claims on October 1, 2015. The original implementation date was October 1, 2014.

Effective September 3, 2014, the Final rule implemented section 212 of the Protecting Access to Medicare Act of 2014 (P.L. 113-93) by pushing back the original compliance date for the ICD-10-Clinical Modification (ICD–10–CM), including the ICD–10–CM Official Guidelines for Coding and Reporting. The Final rule also changed the compliance date for the ICD-10-Procedure Coding System (ICD–10–PCS) for inpatient hospital procedure coding, including the ICD–10–PCS Official Guidelines for Coding and Reporting.


The groups maintained that hospitals and providers had spent billions in preparation for the October 2014 implementation, including the reconfiguration of ICD-10 systems and processes back to ICD-9 processes; the re-training of medical coders who graduated from ICD-10-focused programs and were unprepared to use the older code set; the re-training of existing coders needed given the one-year delay; and outreach initiatives for clinicians.

The AHA noted that the hospitals are ready to work with Congress to ensure that the next implementation date is not missed.