ICD-10 Update

By Kate Riordan February 18, 2015

One of the most important developments in Medicare Secondary Payer compliance for 2015 will be the transition from ICD-9 codes to ICD-10 codes on October 1, 2015. On that date, medical providers will begin using ICD-10 codes.

Last year, in conjunction with the change, CMS announced its ICD-10 transition policy. Click here for a copy of CMS' recent Alerts.

The new CMS ICD-10 policy can be outlined as follows:

  • CMS will require ICD-10 codes to be reported only for “dates of injury” (as defined by CMS in its NGHP User Guide) on or after October 1, 2015.
  • If the date of injury is after October 1, the Responsible Reporting Entity (RRE) must report at least one appropriate ICD-10 code — regardless of the reporting date.
  • If the date of injury is before October 1, the RRE can report either at least one appropriate ICD-9 code or at least one appropriate ICD-10 code.
  • ICD-9 codes — for claims with dates of injury before October 1, 2015 — can be reported regardless of the reporting date.
  • For dates of injury before October 1, 2015, the RRE must be certain to identify the appropriate code as either an ICD-9 or ICD-10 via the ICD Indicator.

CMS policy is relatively simple and, as noted above, is driven purely by the date of injury (again, as that term is defined by CMS in its NGHP User Guide).

Our MSP Navigator™ reporting tool will be ready to accept ICD-10 codes when required. In the meantime, if you have any questions, please do not hesitate to contact the author.

To learn more about our MSP NavigatorTM reporting tool and Section 111 audit service, click here.


Kate Riordan

Kate Riordan is the director of Medicare Secondary Payer (MSP) initiatives at ISO Claims Partners. She has well over five years of experience in completing Medicare Set-Asides and obtaining CMS approvals, with a concentration in California claims. Kate graduated Bowdoin College and Suffolk University Law School and is a Medicare Set-Aside Certified Consultant.