May 18, 2011

CMS: Rumors of I-10 Delay Don’t Hold Water


The rumors “flying around” that the Centers for Medicare & Medicaid Services (CMS) will delay implementation of the new ICD-10 coding systems “don’t hold water,” said Denise Buenning, MsM, director of CMS’s administrative simplification group in the office of E-health standards and services—one of the seven presenters at the May 18 National Provider Teleconference on CMS ICD-10 Conversion Activities.


She emphasized that CMS is “working toward” the implementation date of October 1, 2013, and it is “progressing.” For example, said Buenning, the agency has formed a steering committee that includes 19 affected component areas. Planning and forecasting have begun and staff are “now into the nitty-gritty” of the transition, which includes talking to contractors about changes that must occur, including system requirements and business processes.

As Buenning stated, “This is significant because it sends an important message: If CMS is progressing [toward implementation], the rest of the industry should be too.”

Emphasizing the Timeline

The teleconference included several topics, starting with an outline of key dates by Pat Brooks, RHIA, senior technical advisor for CMS’s hospital and ambulatory policy group.

As the table below shows, goals have been established.



Like Buenning, Brooks emphasized that these dates are “firm.” She also provided a few other important details in the way of just-the-facts:

All providers in every healthcare setting will use ICD-10-CM diagnosis codes.

ICD-10-PCS (procedures) will be used only for claims for inpatient hospital procedures. They will not be used on physician claims, even those for inpatient visits.

The new ICD-10 system will not impact CPT and HCPCS codes, which will continue to be used for physician and ambulatory services including physician visits to inpatients.

ICD-10-CM codes provide greater detail in describing diagnoses and procedures than do ICD-9-CM codes, and, as a result, there are more of them, and they are longer and include alpha characters.

System changes are required to accommodate new ICD-10 codes.

Translating the Lab NCDs

Lisa Eggleston, RN, MS, health insurance specialist in CMS’s coverage and analysis group, led this section of the teleconference. Before explaining the process that she and her colleagues used to translate the ICD-9-CM diagnosis codes into ICD-10-CM diagnosis codes, here’s a quick explanation of the lab national coverage determinations (NCDs) for those who need it.

In November 2001, CMS issued 23 national coverage determinations (NCDs) for clinical diagnostic laboratory services. These policies are different than most other Medicare NCDs in that each one represents one lab test, and each test includes three lists of ICD-9-CM codes: covered codes, not covered codes, and codes that do not support medical necessity.

Getting back to the translation process used, Eggleston explained that the task—a “challenge” as she called it—was to take all of ICD-9 codes included in all 23 lab NCDs and find their equivalent codes in ICD-10-CM. To do this, she and her staff used the general equivalence mappings (GEMs).

However, she emphasized that GEMs are absolutely not the only way to do the translation; they’re just what CMS chose to use. Eggleston also emphasized that GEMs are no substitute for learning how to code using ICD-10. In fact, for some small conversion projects picking up an ICD-10 code book may be easier than using GEMs.

Nonetheless, with the help of GEMs, Eggleston and staff did the following. The handout for the teleconference (see Important Resources below) included examples from one of the lab NCDs for the steps below.

• List all currently covered ICD-9-CM codes for the lab NCD. Ensure that the list is complete.
• Check the translation. Use the most current publicly available GEM files for both forward and backward translation of each covered ICD-9-CM code.
• Merge and de-duplicate forward and back translated versions.
• Compare each proposed ICD-9-CM and ICD-10-CM translation (including descriptors) for consistency.
• List all unique ICD-10-CM codes and descriptors for the specific lab NCD in ICD-10-CM order.

Once completed, CMS will provide the final ICD-10 tables to a contractor, which will prepare a “code list spreadsheet.” This spreadsheet (an internal CMS identifier) can be processed and tested for use by the shared systems for claims processing.



Home Health Agencies

Joan Proctor, health insurance specialist for the chronic care policy group, admitted that the CMS division responsible for HHAs only had a “high-level transition plan” and that it was nowhere as far along as the above group. The plan includes the following steps, which will be completed by CMS’s internal deadline of April 2013:

• Identify ICD-10-CM codes for the home health resource grouper (HHRG).
• Post a draft form on CMS web site and invite industry comment.
• Post draft HHRG and commence vendor testing.

Questions Remaining

Even though the teleconference made it clear that CMS is, indeed, making progress, it also made it clear that there are still many unanswered questions for agency staff as well as providers. For example, here’s one question that CMS continues to hear: Do vendors have products ready for customers yet?

In a mini-survey conducted by CMS in March, vendors told CMS that they do have products now or will shortly, but providers aren’t ready. Providers tell CMS that they’re ready but vendors aren’t. CMS staff is trying to clear logjams such as this and plans to conduct another larger survey in June of 1,200 entities to monitor industry progress.

Important Resources

In addition to more details of the above, the handout for the teleconference includes many important educational and informational web sites that providers will want to utilize. To download the presentation, go to, and check under the date column for 5/18/11. Also, in two to three weeks, providers may download a transcript of the teleconference at

Read 10 times Updated on March 16, 2016
Janis Oppelt

Janis keeps the wheel of words rolling for Panacea®'s publishing division. Her roles include researching, writing, and editing newsletters, special reports, and articles for and; coordinating the compliance question of the week; and contributing to the annual book-update process. She has 20 years of experience in topics related to Medicare regulations and compliance.