A “new and improved” normal: Changes for April 1 update announced

Last year, the Centers for Medicare & Medicaid Services (CMS) and the National Center for Health Statistics (NCHS) jointly finalized a proposal to make the April 1 update of ICD-10-CM/PCS a normal thing instead of an emergency, once-in-a-blue-moon thing. Beginning in 2021, ICD-10 will be updated twice a year, on April 1 and Oct. 1. Previously, new diagnosis or procedure codes could only be added for specific reasons—to track an emerging disease or to track procedures that met strict criteria for a mid-year update.

This year, the April 1 update consists largely of COVID-19 related codes—three diagnosis codes and four procedure codes. Here are the COVID-19 related codes:

New diagnosis codes for April 1—COVID-19 vaccination status

• Z28.310 Unvaccinated for COVID-19
• Z28.311 Partially vaccinated for COVID-19
• Z28.39 Other underimmunization status

In the version of Medicare severity-diagnosis-related groups (MS-DRGs) to accompany the April 1 update, V39.1, the diagnosis codes are classified as non-CC and are assigned to DRG 951 in MDC 23.

Below are the procedure codes for April 1, and for convenience I have divided them into two groups—COVID-19 related procedure codes, followed by other procedure codes.

New procedure codes for April 1—COVID-19 vaccine administration

• XW013V7 Introduction of COVID-19 vaccine dose 3 into subcutaneous tissue, percutaneous approach, new technology group 7
• XW013W7 Introduction of COVID-19 vaccine booster into subcutaneous tissue, percutaneous approach, new technology group 7
• XW023V7 Introduction of COVID-19 vaccine dose 3 into muscle, percutaneous approach, new technology group 7
• XW023W7 Introduction of COVID-19 vaccine booster into muscle, percutaneous approach, new technology group 7

Because the April 1 update can now include any new code request that specified an April 1 implementation date and received public support, the April 2021 update also contains three procedure codes for administration of a drug under the New Technology Add-On Payments (NTAP) program. These codes could not have been included in an April 1 update under the previous, more stringent requirements. It is very likely that the April 1 updates will be more extensive in the years to come, as more requesters ask for an April 1 implementation date.

New procedure codes for April 1—Fostamatinib administration

• XW0DXR7 Introduction of fostamatinib into mouth and pharynx, external approach, new technology group 7
• XW0G7R7 Introduction of fostamatinib into upper GI, via natural or artificial opening, new technology group 7
• XW0H7R7 Introduction of fostamatinib into lower GI, via natural or artificial opening, new technology group 7

All seven of the new ICD-10-PCS codes for April 1 are classified as non-OR and so are not assigned to a DRG in MS-DRGs.

Below, I will point out a few general things about the April 1 code update files. It may strike some of you as painful elaboration of the obvious, but others may find it useful to have these details confirmed, since this is our first regular April 1 update. I am going to focus on the procedure code update files for two reasons: because I work on the 3M team under contract with CMS to assist with the ICD-10-PCS update, and because the ICD-10-PCS update files are already posted on the CMS website. They were posted Dec. 2, to give the public plenty to time to get ready for April 1.

• The update files and the file formats for each file are the same for the April 1 update as for the Oct. 1 fiscal year update. I mention this because the emergency updates posted in 2020 contained ad hoc files announcing individual changes, sometimes only a PDF document announcing a new code or codes. To use a well-worn phrase, those were unprecedented times; these are precedented times, and I use the word “precedent” in the literal sense. Regularizing the April 1 update was preceded by the long-established federal regulatory process: An annual April 1 update was formally proposed in rulemaking, then finalized after receiving and considering public comment, in accordance with the federal regulatory process.
• April 1, 2022, is still the 2022 fiscal year. This means the individual download files are labeled 2022 and any reference to year in titles or labels within the files says 2022.
• As one would expect, the April 1 update ICD-10-PCS addenda files (codes_addenda_2022, definitions_addenda_2022, index_addenda_2022, order_addenda_2022 and tables_addenda_2022) only contain the changes for the April 1 update. The April 1 update addenda files do not contain the accumulated changes for all of fiscal year 2022, because the changes valid Oct. 1, 2021 have long been released and implemented in systems and applications … and because it would be super confusing and annoying to repeat that information as if it were new.
• As one would also expect, all other files contain the full content of the ICD-10-PCS for fiscal year 2022 as of April 1, 2021. Why? Because updates are cumulative; like the annual Oct. 1 update, the full content files contain all valid codes and associated information/coding instruction in effect on that date.

I mentioned earlier that the MS-DRGs will also release an updated version for April 1, to accommodate the new codes. The April 1, 2022, version of MS-DRGs is V39.1, and the Grouper Software, Definitions Manual and Medicare Code Edits will be available on this page on the CMS website.

Updated ICD-10-CM diagnosis files for changes that go into effect April 1, 2022, will be available on the CDC website.

Based on public comments made during the September Coordination and Maintenance (C&M) meeting, having twice annual updates to ICD-10 is generally considered a significant and long overdue improvement in the ICD-10 update process. Given the pace at which the understanding of disease and health care innovation progresses, two updates a year is still too few—but it’s better than one.

Rhonda Butler is a clinical research manager with 3M Health Information Systems.

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