Effective April 1, 2023, ICD-10-PCS update: Working toward balance

If there is one word that captures what many of us want to focus on in 2023, I think “balance” is a good candidate. From global issues like the climate emergency and the gap between the well-off and vulnerable, to individual and personal challenges like finding a sustainable rhythm for your day, balance is a thing eminently worth working toward. 

On a modest scale, the Centers for Medicare & Medicaid Services (CMS) is working toward balance with the recent change to a twice annual update of ICD-10. This year is the second regular April 1 update for ICD-10-CM/PCS, a change made so that ICD-10 can respond in a timelier way to changes in our understanding of disease and techniques for treating it.  

So far, though, the public isn’t taking full advantage of the additional update. The April 1 update is still much smaller than the Oct. 1 update. This year’s PCS update contains more new codes than last year—34 codes compared to seven codes. Hopefully that trend will continue, but it is still far from anything like balance.  

One of the things CMS did this year to work toward balancing the size of the April and October updates is to have all September coordination and maintenance (C&M) committee meeting addenda proposals included in the April 1 update (if supported by public comment) regardless of whether the change was specifically requested for April 1 implementation or not. This policy tweak accounted for 32 of the 34 new codes. Addenda items are proposed changes to existing code tables, index entries or definitions, submitted by coders or other stakeholders, that do not require a clinical presentation during the C&M meeting or a detailed background paper in the agenda.  

The addenda proposals constitute one agenda item. All other code proposals on the agenda require that the requestor ask for an April 1 implementation date. They do not have to give a reason—they just need to ask. So, a further way to balance the workload between the April update and the October update would be to make April 1 the default implementation date for all proposals presented at the September meeting, just like Oct. 1 is the default for all proposals at the March meeting. However, it may not be possible for CMS to do that without further regulatory changes.  

Another factor in balancing the size of the April and October updates is the number of proposals presented at the March C&M meeting versus those presented at the September meeting. The March agenda consistently has had more proposals than the September agenda—and lately it has had a lot more. Last year there were 29 agenda items in March and nine agenda items in September, more than three times more. And of course, all items on the March agenda are not eligible for the April 1 update as it is posted in January, like the Oct. 1 update is posted in June.  

Why do requestors consistently pile on to the March meeting and not the September one? The deadline for submitting March C&M requests is early December of the previous year, and for the September C&M meeting the deadline is early June of the current year. I can’t see the December deadline as obviously preferable, but perhaps deadlines for the Food and Drug Administration (FDA) approval process or the New Technology Add-on Payment (NTAP) submission process are a factor. I don’t know.  

What I do know is that these processes are quite involved, and that, it seems, is inevitable with human-designed processes. Over time complexity tends to increase as each work generation makes its mark on a process. 

For those interested in the details of the ICD-10-CM/PCS changes in the April 1 update, it was posted Jan. 11. You can download the procedure code update on the CMS website at  2023 ICD-10-PCS and the diagnosis code update on the National Center for Health Statistics (NCHS) website at Comprehensive Listing ICD-10-CM Files (cdc.gov). You can download both sets of updates on the CMS website, but if I give you that link instead, it adds to the already widespread impression that CMS has responsibility for the diagnosis code set. The last thing I want to do is add to that confusion! But that is another story. 

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