The first step is to identify a need for the new code or a revision of a current code.
Anyone can petition for a new ICD-10-CM or ICD-10-PCS code. ICD-10-CM is administered by the Centers of Disease Control and Prevention (CDC) and ICD-10-PCS is administered by the Centers for Medicare and Medicaid Services (CMS). Each of the websites has posted the process for requesting a new code.
The first step in the process is to identify a need for the new code or a revision of a current code. This step can be determined by a private citizen, a company, healthcare organization, or governmental agency. The CDC and CMS proposals are maintained on their respective websites and these documents are wonderful guides in completing the request for a new code. This step ends with the completion of the application for a new code which can be found on the CDC or CMS websites.
The application for a new code requires a description of the new code and why the code is needed. The applicant will need to describe the reasoning for the new code and provide some alternative code options. It is advisable to have clinical support for the new code. The clinical support will include a description of the disease, its treatment, and how the new code will be utilized. Supporting clinical literature should also be submitted with the application. The application for the new code is forwarded to the Coordination and Maintenance Committee. The Coordination and Maintenance Committee will assign a classification expert to assist the application through the process. The application is submitted at least three months prior to the Coordination and Maintenance Committee meeting.
The application is reviewed at Coordination and Maintenance Committee. Any questions will be sent to the applicant. There are pre-meetings to determine if the application is accepted or rejected. As stated before CDC will review requests for new diagnosis codes and CMS will review the applications for new procedure codes. Coordination and Maintenance Committee will determine if the application has merit and inform the applicant of acceptance or rejection. The next step is to present at Coordination and Maintenance Committee meeting in March or September.
The presentation at Coordination and Maintenance Committee includes a clinical presentation and potential code options. Usually, the clinical presentation is completed by a physician. The code options are reviewed by the CDC or CMS. In the recent years, the meetings have been virtual, but in the past attendees could be present in person. During the presentation, attendees can ask questions about the code or about the clinical information. This time is ideal to understand the “spirit” of the code. Coders can learn about why a code has been requested and the reasoning for collecting the data.
The Coordination and Maintenance Committee meeting is not the end of the code application. After the presentation at the public meeting, the public can send comments regarding the new code requests. The Coordination and Maintenance Committee may request additional information from the applicant to respond to these questions.
As an applicant, when you see the published proposed codes then you know if your application has been successful. There is a period after the published proposed code for additional comments to be submitted. The final codes are published in June. If the application is rejected, the application can be revised and submitted for consideration later. The process can take six months or longer until the codes are finalized.
The coming year will be a little different as Final Rule for Inpatient Prospective Payment System (IPPS) FY22 published the acceptance of an April 1st code release beginning with April 1, 2022. The process for the publication of final codes for implementation April 1st has not yet been revealed.
The Coordination and Maintenance Committee Meeting on Sept. 14 and 15 should provide more detailed information regarding this process.
Programming Note: Listen to Laurie Johnson’s Coding Report on Talk Ten Tuesdays every Tuesday, 10 Eastern.
Resources: https://www.cdc.gov/nchs/icd/icd10_maintenance.htm#Submission
https://www.cms.gov/Medicare/Coding/ICD10/newrevisedcodes
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