The US ICD-11 Implementation

When will ICD-11 be implemented for morbidity reporting in the US? That’s a question everyone wants the answer to, but the answer is not yet known and there is presently too much uncertainty to accurately predict an implementation date.

The World Health Assembly adopted ICD-11 in May 2019. Anticipating that, the HHS Secretary tasked the National Committee on Vital and Health Statistics (NCVHS) with evaluating pathways and making recommendations on the adoption and use of ICD-11 in the U.S. In August 2019, the NCVHS subcommittee on standards held an ICD-11 expert roundtable. This meeting was the beginning of the NCVHS ICD-11 transition planning.

The NCVHS has recommended to HHS that they simplify the transition and use a sub-regulatory process to move from ICD-10-CM to ICD-11, in the same way that it makes version updates to all the other named HIPAA standards. It will be interesting if HHS accepts this recommendation as that would likely speed up the switch if it’s merely a version update, rather than a regulatory process. NCVHS has also recommended that HHS clarify that ICD-10-PCS will not be updated with the transition of ICD-10-CM to ICD-11. 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. This would officially un-couple the two code sets, which has some drawbacks for managing code changes, but would further simplify the move to ICD-11.

Based on the roundtable meeting in August, the NCVHS is producing a set of questions to help guide HHS in developing research to inform evaluation of the cost and benefit of transition from ICD-10-CM to ICD-11 for morbidity reporting. The research questions will include for example assessment of whether a US clinical modification of ICD-11 will need to be developed. This question is a key to estimating an implementation timeline since the need to develop a clinical modification (rather than simply identifying a subset of ICD-11 codes for use in the US, i.e. a US “linearization”) would delay implementation by several years.

Though the timing remains largely uncertain, planning for the transition to ICD-11 is certainly underway. And one other thing is certain, it’s imperative to monitor ICD-11 planning since coders may need to prepare differently for ICD-11 than they did for the transition to ICD-10. ICD-11 is designed to be computable and is expected to facilitate greater auto-generation of codes from clinical documentation. Of course, we’ve heard that before however CAC applications have yet to live up to such expectations and there doesn’t appear to be changes in procedural coding on the horizon. Still the machine computable design of ICD-11 may well be the catalyst that indeed significantly changes coding professionals’ roles. ICD-11 could mean that coders transform to auditing roles for diagnosis coding or take on other data quality assurance responsibilities. This supports HIM experts’ opinions that HIM professional’s ability to identify data patterns will be an important skill as automation advances and additional skills in data analysis tools and techniques are needed to prepare for those opportunities.

Stay tuned as ICD-11 transition planning continues. We’ll be keeping an eye on developments and preparing ourselves to help healthcare systems like yours accomplish smooth and efficient ICD-11 implementations. Subscribe to our blog to follow along as we share what we learn. And, if you’d like to learn more about the structure and implications of ICD-11, click here to contact us today.

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