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Arriving Soon: Code U09.9, Post-COVID-19 Condition

The new code is expected to be here in October.

EDITOR’S NOTE: The following is the broadcast script from Dr. Erica Remer’s segment during Talk Ten Tuesdays, March 16, 2021.

One of the highlights of my year, and most definitely in this past year, is participating in the ICD-10-CM Coordination and Maintenance Committee Meeting. It was held via Zoom and recorded, so you can view it after the fact (, although at the time of publishing this article, it had not been posted yet.

The code I am going to introduce to you is a code to supplement B94.8, Sequelae of other infectious and parasitic diseases. Some of you may remember I have been suggesting a highly unorthodox approach to signify that the “other infectious and parasitic disease” is COVID-19. I had been recommending using Z86.16, Personal history of COVID-19 as an additional code despite the admonition to not do so from the American Hospital Association (AHA).

The World Health Organization (WHO) created the ICD-10 code, U09.9, which is being proposed to be adopted into ICD-10-CM (the United States’ version of the classification system) without modification. WHO named it, ‘Post COVID-19 condition, unspecified,’ and their instructional note says, “this optional code serves to allow the establishment of a link with COVID-19. This code is not to be used in cases that still are presenting COVID-19.”

There will be an instruction to “Code first the specific condition related to COVID-19, if known, such as: chronic respiratory failure, J96.1-, loss of smell and taste, R43.8.” The expected implementation date is October 1, 2021.

My comments included the following:

  • Hooray for a way to specify which infectious and parasitic disease was the culprit!
  • Are you sure you can’t get this one into the codebook even sooner?
  • Inclusion terms need to include post-acute sequela of COVID-19, PASC, sequela of COVID-19, long-haul COVID-19, long COVID-19
  • I recommend adding G93.3, Postviral fatigue syndrome as one of the code-first conditions listed as examples
  • At M35.81, Multisystem inflammatory syndrome, they need to add U09.9 as a choice for an additional code to signify COVID-19 linkage. In fact, I think it should outright replace the option of B94.8 which is misleadingly referred to as “sequelae of COVID-19.”
  • They should translate the note saying, “This code is not to be used in cases that still are presenting COVID-19” into American English. What they are trying to convey is if the patient has a current, acute, active case of COVID-19, U09.9 cannot be applicable from the same infection. I think it is possible to have U09.9 from a previous COVID-19 infection and then get reinfected, perhaps with a different variant, so an EXCLUDES1 note might not be optimal.

Please look at the proposals reviewed on March 10 yourself (  and submit your own comments by April 9 (

It is interesting to note that WHO’s ICD-10 has all its dedicated COVID-19 codes in the same vicinity. U08.9 is their personal history code, U10.9 is a specific MISC-associated-with-COVID-19 code, U11.9 is the code they use for indicating a patient encounter for COVID-19 vaccination, and U12.9 specifies adverse effects from COVID-19 vaccines. We housed our personal history code in ICD-10-CM with other personal history Z codes and didn’t create corresponding COVID-19 specificity for the other conditions.

Finally, the AHA/AHIMA COVID-19 FAQs (, which were most recently updated on March 1, have a question (#43) relating to documentation of “post COVID-19 syndrome,” and the answer states that this was not indicating linkage but temporality. In my opinion, a provider who documents post COVID-19 is trying to convey causality and not a time reference. I suggested that post COVID-19 syndrome be included in U09.9 as well.

It is really amazing to be living through this time. Codes are being developed and rolled out in record speed. However, I hope we never get to experience it again in the future. Once has been more than enough for me.

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Erica E. Remer, MD, CCDS

Erica Remer, MD, FACEP, CCDS, has a unique perspective as a practicing emergency physician for 25 years, with extensive coding, CDI, and ICD-10 expertise. As physician advisor for University Hospitals Health System in Cleveland, Ohio for four years, she trained 2,700 providers in ICD-10, closed hundreds of queries, fought numerous DRG clinical determination and medical necessity denials, and educated CDI specialists and healthcare providers with engaging, case-based presentations. She transitioned to independent consulting in July 2016. Dr. Remer is a member of the ICD10monitor editorial board and is the co-host on the popular Talk Ten Tuesdays weekly, live Internet radio broadcasts.

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