Statement From Internists on CMS' Contingency Plans for ICD-10

Attributable to:
Wayne J. Riley, MD, MPH, MBA, MACP
President, American College of Physicians

(Washington, July 6, 2015) The implementation of the International Classification of Disease, 10th Revision Clinical Modification (ICD-10 CM) is scheduled to go into effect on Oct. 1, less than 90 days from now. The transition is necessary because accurate ICD-10 coding will more closely reflect the severity of illness and help substantiate medical necessity, contribute to health-care quality and improvement initiatives, and advance public health research and emergency response. However, ACP understands that this transition will have a profound impact on the physician community, and wants the transition to be as successful and seamless as possible. Therefore, ACP has actively worked with the American Medical Association (AMA) and other medical societies to encourage CMS to establish alternate plans to mitigate any unintended consequences on physicians. ACP is very pleased to acknowledge that CMS has responded by establishing a contingency plan for the physician community.

The change from ICD-9 to ICD-10 is one of the largest technically challenging transitions for physicians in the past several decades. Although the coding conventions in ICD-10 are similar to those used in ICD-9 there are many differences. Undoubtedly, these differences will create opportunities for errors in coding accuracy. Therefore, ACP appreciates that CMS has directed the Medicare Administrative Contractors (MACs) and Recovery Audit Contractors (RACs) not to reject or deny claims based solely on an error due to the lack of accuracy or specificity within the appropriate code family during this transition.

This contingency plan also will help dispel some concerns about how ICD-10 transition in Oct. will occur during the 2015 reporting periods for the Medicare Physician Quality Reporting System (PQRS), Value-Based Payment Modifier, and Electronic Health Record (EHR) Meaningful Use (MU) programs by continuing to allow the use of ICD-9 codes for those measures until the end of the year. It is reassuring to see CMS recognize this problem and put in place an alternative plan to account for any significant differential in satisfactorily reporting quality measures between the two code sets.

Finally, ACP appreciates that in the event Medicare contractors are unable to process claims within established time limits due administrative problems or system malfunctions that are not the fault of the physician, CMS will authorize advance payments to the effected physicians.

For additional assistance on ICD-10 please visit the ACP website or contact Brian Outland or Margo Williams in the ACP Washington office.


The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 143,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter and Facebook.

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