Proposed Biannual ICD-10 Implementation Dates: Weighing the Pros & Cons 

Understanding the impact on business processes in the event that biannual ICD-10-CM and PCS updates are implemented is essential – as is your feedback. 

With a comprehensive agenda covered at the virtual ICD-10 Coordination and Maintenance Committee meeting earlier this month, one topic in particular inspired quite a few comments and engagement from attendees.

The Centers for Medicare & Medicaid Services (CMS) and the Centers for Disease Control and Prevention’s National Center for Health Statistics (CDC/NCHS) announced a proposal for introducing an April 1 implementation date for ICD-10-CM diagnosis and ICD-10-PCS procedure code updates.

As presented, “the April 1 code update would be in addition to the existing Oct. 1 update under section 1886(d)(5)(K)(vii) of the Social Security Act for diagnosis or procedure code revisions needed to describe new technologies and medical services for purposes of the new technology add-on payment process.”

If this occurs, the process would require that requestors specify which of the two implementation dates they intend for their proposed changes.

Purportedly, the ICD-10 Coordination and Maintenance Committee would make efforts to accommodate the requested implementation date for each request submitted. However, the Committee would make the determination of which requests would be presented for consideration for April 1 or Oct. 1.

It came as no surprise that the proposal of biannual ICD-10 implementation dates brought about numerous comments during the meeting, with discussions centering on various pros and cons of such an adjustment. First, there are several updates already occurring during the month of April. Add to that new technology features and all that is happening behind the scenes, like with PCS. And though CPT changes become active on Jan. 1, many organizations are still handling changes months later, with delays ranging from system constraints to operational challenges.

On the other hand, this could be a good thing. After all, we have been using the same system with the Oct. 1 date since the inception of ICD-10. Improving efficiencies and enhancing processes is always a positive, even with the expected challenges.

If we learned anything from the COVID-19 pandemic, it’s that we are capable of making swift changes and process improvements. In an extremely limited amount of time, COVID brought about accelerated shifts in healthcare – and all business sectors. Healthcare, in particular, stood up to the test to meet new coding requirements and adjust to processing modifications. Most found that they were able to implement the changes far more quickly than they ever thought possible. The good news is, there is still time to evaluate, and CMS has opened up public comment.

Committee meetings provide a public forum to discuss proposed changes to ICD-10, but no final decisions are made at the meeting. “We are also seeking input on what factors the Committee should consider,” CMS noted, “when determining which requests should be considered for either an April 1 or Oct. 1 implementation date.”

The Committee clarified that the earliest date an April 1 code update option would be considered is April 1, 2022. Comments must be submitted by May 7, 2021, to the CMS mailbox at 


Susan Gatehouse, RHIT, CCS,CPC, AHIMA-Approved ICD-10-CM/PCS Trainer

Susan Gatehouse is the founder and chief executive officer of Axea Solutions. An industry expert in revenue cycle management, Gatehouse established Axea Solutions in 1998, and currently partners with healthcare organizations across the nation, to craft solutions for unique challenges in the dynamic world of healthcare reimbursement and data management.

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