Suspension of code changes prior to and following implementation of ICD-10

TO: Members of the ICD-9-CM Coordination and Maintenance Committee
FROM: The American Academy of Professional Coders (AAPC)
RE: AAPC’s position regarding suspension of code changes prior to and following implementation of ICD-10-CM and -PCS

The American Academy of Professional Coders does not support the freezing of changes to ICD-9-CM prior to the Oct. 1, 2013 implementation of ICD-10-CM and ICD-10-PCS. Because changes to other coding systems, specifically CPT and HCPCS Level II, will be required regardless of any change in ICD-9-CM code change scheduling, AAPC can see no benefit to freezing ICD-9-CM. And because medical science is continually evolving, AAPC believes any freeze of updates to diagnostic coding affects reporting accuracy and should be limited.

AAPC supports a freeze in changes to ICD-10-CM and ICD-10-PCS. Because all users will be setting up entirely new systems to accommodate ICD-10-CM and ICD-10-PCS in the year(s) prior to implementation, AAPC supports a freeze on changes to the ICD-10-CM and ICD-10-PCS code sets beginning Oct. 1, 2012 (one year prior to implementation) and continuing until Oct. 1, 2014 (one year following implementation). This will provide a 24-month hiatus from any changes to the new system, which will ease the burden of adoption for all participants.


Thank you for the opportunity to contribute to the discussion on this very important topic. AAPC will be in attendance to the Coordination and Maintenance Committee meeting September 16 and 17 in Baltimore.

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