ICD-11 Implementation Date

When will we implement ICD-11 for use on healthcare claims in the US? That’s a question everyone wants the answer to, but the true answer is – no one knows. However, when we know the answer on the following three key questions, we’ll be able to predict the implementation date in the US.

Will the US create a clinical modification of ICD-11?
If the US decides that a clinical modification of ICD-11 is needed, that will take several years to develop. However, if the US can identify a subset of codes from the WHO ICD-11 Foundation entities for use in the US, i.e. define a US “linearization” of ICD-11, that would speed up implementation by several years.

Will the transition be a version update or a regulatory change?
The need for regulatory action is one of the things that held up the move to ICD-10-CM for a decade or more. For ICD-11, the NCVHS recommended to HHS that they simplify the transition and use a sub-regulatory process, in the same way that it makes version updates to all the other named HIPAA standards. If HHS accepts this recommendation, that will also speed up implementation as ICD-11 will simply be a version update.

Will the US update ICD-10-PCS at the same time?
What we decide to do about the procedure code set will also impact the speed of adoption. The ICD-10-PCS procedural coding system is a completely separate system from ICD-10-CM and is not tied to ICD-10-CM, nor is it based on the WHO’s ICD system. The US could un-couple the two code sets, which has some drawbacks for managing code changes, but would further simplify the move to ICD-11.

Though the timing remains largely uncertain, planning for the transition to ICD-11 is certainly underway. And when you see decisions on any of these three points, you’ll know we’re making real progress.