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Preparing for the ICD-10 transition

By Mark Popolizio  |  August 7, 2014

The Centers for Medicare and Medicaid Services (CMS) released an alert in May 2014 announcing that the ICD-10 diagnosis codes reporting for Section 111 is postponed until October 1, 2015. A copy of the CMS alert can be obtained here.

Medicare Act prompts delay

The delay in transitioning from ICD-9 to ICD-10 codes is a result of the Protecting Access to Medicare Act of 2014 (Pub. L. No. 113-93), which precludes the Department of Health and Human Services (HHS) from using ICD-10 diagnosis codes before October 1, 2015.

As part of this alert, CMS has outlined the following timeline:

Before October 1, 2015

ICD-9 Diagnosis Codes

  • RREs are to postpone reporting ICD-10 diagnosis codes on their production Claim Input Files and Direct Data Entry (DDE) submissions until October 1, 2015.
  • RREs may submit ICD-9 diagnosis codes only on their production Claim Input Files and DDE submissions.
  • The ICD Indicator field must contain a space or a “9” on Claim Input File Detail Records.
  • The Diagnosis Code Indicator field must be set to ICD-9 for DDE submissions.

ICD-10 Diagnosis Codes

  • ICD-10 diagnosis codes will NOT be accepted on production Claim Input File Detail Records or DDE submissions.
  • ICD-10 diagnosis codes will be accepted on test Claim Input File Detail Records.

Starting October 1, 2015

CMS Date of Incident before 10/1/15

  • ICD-9 or ICD-10 diagnosis codes will be accepted on all add and update records.

CMS Date of Incident 10/1/15 and Subsequent 

  • ICD-10 diagnosis codes required on all production Claim Input Files and DDE add and update records.

Other requirements

  • When ICD-10 diagnosis codes are submitted on Claim Input Detail records, the ICD Indicator field must contain a zero.
  • When ICD-10 diagnosis codes are submitted via DDE, the Diagnosis Code Indicator field must be set to ICD-10.

HHS recently released its final rule regarding ICD-10 transition and implementation. Obtain a copy of the final A copy of this final rule can be obtained here.


Mark Popolizio is vice president of MSP compliance and policy at ISO Claims Partners, a Verisk business. You can contact Mark at mpopolizio@verisk.com.