Statement in Support of Prompt Adoption of ICD-10-CM and ICD-10-PCS Medical Code Set Standards in the United States

Approved by Board of Directors, American Health Information Management Association, July 2003

Support of Prompt Adoption of ICD-10-CM and ICD-10-PCS Medical Code Set Standards in the United States

AHIMA's Position

AHIMA calls upon the Department of Health and Human Services (HHS) - the code set maintenance organization for the United States - and the healthcare industry to take quick and decisive action to expedite the adoption and implementation of ICD-10-CM and ICD-10-PCS1 code sets, rules, and guidelines as a replacement for ICD-9-CM in order to ensure the collection of accurate and complete healthcare data that accurately reflects the healthcare of this country.

Accurate, detailed healthcare information is crucial for:

  • Healthcare clinical decision-making and communication
  • Health research and treatment development
  • Public health and bioterrorism monitoring and response
  • Healthcare management and policy decision-making such as actuarial premium setting, cost analysis, and service reimbursement2
Continued use of ICD-9-CM as a medical code set standard threatens to jeopardize the ability of the US healthcare industry to effectively collect and use accurate, detailed healthcare data and information for the betterment of domestic and global healthcare.

AHIMA calls for the following action to be taken:

  • Immediate decision-making and regulation-setting by the HHS Secretary for the adoption of ICD-10-CM for diagnostic coding in all healthcare settings and ICD-10-PCS for coding of hospital inpatient services with implementation in 2005.
  • Support from the US Congress, in the form of legislative authority (if needed), with financial allocation to HHS and healthcare providers and health plans for adoption and implementation of these code sets, rules, and guidelines.
  • Recognition by the healthcare professionals and the industry of the need for 21st century coding standards and the subsequent benefits to the US population and the healthcare industry of complete, accurate, and standard healthcare data and information.
  • Just as medical care is not provided the same way it was 24 years ago, when ICD-9-CM was implemented, healthcare diagnoses and services cannot be described using 24-year-old medical codes. These outdated codes provide inaccurate or limited data and insufficient detail related to health diagnoses, procedures and technologies.
  • Considerable cost savings and improved patient care will be achieved through more accurate, complete, and detailed data provided by better coding systems. This will improve the ability to measure the quality, safety, and efficacy of healthcare and enhance health policy decision-making.3
  • By delaying the adoption of more contemporary code set standards to replace the outdated ICD-9-CM diagnosis and procedure codes, the US continues to incur unnecessary personal healthcare costs and other related expenses while forfeiting the benefits offered by more advanced and relevant coding systems.
  • ICD-9-CM is ambiguous and lacks precision and the desired level of flexibility. The need to replace ICD-9-CM was identified ten years ago, in 1993, when the National Committee on Vital and Health Statistics (NCVHS) reported that ICD-9-CM was rapidly becoming outdated and recommended immediate US commitment to developing a migration to ICD-10 for morbidity and mortality coding. Similarly, the Health Care Financing Administration (HCFA), now the Centers for Medicare and Medicaid (CMS), recommended that steps should be taken to improve the flexibility of ICD-9-CM or replace it with a more flexible option sometime after the year 2000.
Current Situation

The ICD-9-CM coding standard is irrevocably broken and must be replaced soon.

  • Implemented in 1979, ICD-9-CM no longer meets the most basic definition of "fitness for use," and no longer fits with the 21st century healthcare system:
    • Terminology and classification of numerous conditions and procedures are outdated and inconsistent with current medical knowledge and application. ICD-9-CM is unable to meet this country's current healthcare data needs because the uses of coded clinical data today go well beyond the purposes for which the system was designed or even contemplated in the 1970s3. Therefore, the system is unable to adequately accommodate new advances in medicine and medical technology.
    • ICD-9 (the international system on which ICD-9-CM is based) is not supported (similar to software version support) or maintained by the World Health Organization (WHO). Most of the world uses ICD-10.
  • Data incomparability continues to increase globally and within the U.S. due to the use of different code sets.
  • ICD-9-CM does not meet the requirements for code set standards stipulated by the 1996 Health Insurance Portability and Accountability Act (HIPAA) or the characteristics of a procedural coding system outlined by the NCVHS.3
  • Significant costs (direct and indirect) are being incurred by continued use of severely outdated and limited coding systems. For example, failure of our coding systems to keep pace with medical advances results in the use of vague or incorrect codes and excessive reliance on supporting paper documentation (attachments).3
  • ICD-10-CM and ICD-10-PCS represent a significant improvement over ICD-9-CM, because they were specifically designed to replace ICD-9-CM, and resolve many of the problems inherent in ICD-9-CM. ICD-10-CM and ICD-10-PCS:
    • Reflect advances in medical care and knowledge that have occurred since the implementation of ICD-9-CM in 1979.
    • Are sufficiently flexible to allow future expansion to readily accommodate medical advances, ensuring that the systems will remain useful well into the future.
    • Meet HIPAA criteria for code set standards and NCVHS criteria for a procedural coding system.
    • Are the only viable replacement options at the present time.

Background - Code Set Development and Maintenance


  • Is comprised of Volumes I and II (diagnosis codes) and Volume III (procedural codes). It is used in the US for diagnosis coding for morbidity purposes in all healthcare settings and procedural coding in the hospital inpatient setting.
  • The diagnosis code component is a US modification of the WHO's International Classification of Diseases (ICD) and is maintained by the Center for Disease Control and Prevention's (CDC's) National Center for Health Statistics (NCHS). WHO no longer supports ICD-9.
  • The procedural code component was developed and is maintained by CMS.
  • The ICD-9-CM Coordination and Maintenance Committee is an open, public body responsible for making changes in the ICD-9-CM code set.
ICD-10-CM and ICD-10-PCS:
  • ICD-10-CM is a US clinical modification of WHO's ICD-10 and is maintained by NCHS. ICD-10 is now implemented or being implemented in all highly developed nations except the US. In the US, ICD-10 has been used to report mortality data at a state and national level, since 1999.
  • ICD-10-PCS was designed in the 1990s under contract by the CMS, specifically to replace the ICD-9-CM procedural coding system. It is not derived from an international coding system, but is designed to reflect the use of current and future technology changes.
  1. ICD-10-CM stands for the International Classification of Diseases, Tenth Revision, Clinical Modification (a US version of ICD-10 developed by the World Health Organization.) ICD-10-PCS is a procedural coding system designed by the Centers for Medicare and Medicaid to replace the current inpatient procedural coding system included in ICD-9-CM.
  2. See AHIMA's Position on Consistency of Healthcare Diagnostic and Procedure Coding,
  3. AHIMA Testimony on ICD-10-PCS and ICD-10-CM before the National Committee on Vital and Health Statistics Subcommittee on Standards and Security (April 9, 2002 and May 29, 2002),

The American Health Information Management Association is a dynamic organization of over 45,000 specially educated professionals, working throughout the healthcare industry, to ensure accurate and timely information to benefit the public, providers, and others who utilize clinical data.