Coding Around the Compliance Date

With the ICD-10 compliance date less than 10 days away, your practice may already be seeing patients whose claims will be submitted after the October 1 compliance date.

Remember that if the date of service was before October 1, 2015, you must submit the claim with the appropriate ICD-9 diagnosis code—even if you submit the claim on or after the ICD-10 compliance date.

For hospital inpatient reporting, “date of service” is defined as date of discharge.

The requirements outlined here apply to Medicare Fee-For-Service. More information is available on the ICD-10-CM/PCS Frequently Asked Questions web page. For questions about commercial and other government insurance plans, please check with the specific plan.

Should I Use ICD-9, ICD-10, or Both?
A claim cannot contain both ICD-9 codes and ICD-10 codes. Medicare will not pay claims containing both ICD-9 and ICD-10 codes.

  •  For dates of service prior to October 1, 2015, submit claims with the appropriate ICD-9 codes.
  •  For dates of service on or after October 1, 2015, submit with the appropriate ICD-10 codes.

Further guidance about coding with ICD-10 around the deadline is available inMedicare Learning Network Article SE1408.

What About Claims Spanning the Compliance Date?
CMS has guidance for providers dealing with claims spanning the compliance date:

  •  MLN Matters SE1325 - Institutional services split claims billing instructions for Medicare Fee-For-Service (FFS) claims that span the compliance date
  •  MLN Matters SE1408 – Medicare FFS claims processing guidance for implementing ICD-10
  •  MLN Matters SE1410 – Special instructions for ICD-10-CM coding on home health episodes that span the compliance date

Will CMS Allow for Dual Processing?
CMS will not allow for dual processing of ICD-9 and ICD-10 codes after ICD-10 implementation on October 1, 2015. Many providers and payers, including Medicare, have already coded their systems to allow only ICD-10 codes beginning October 1, 2015. The scope of systems changes and testing needed to allow for dual processing would require significant resources and could not be accomplished by the October 1, 2015, implementation date. For more information, see CMS FAQ 12430.

Keep Up to Date on ICD-10
Visit the CMS ICD-10 website and for the latest news and resources to help you prepare, including the ICD-10 Quick Start Guide. Sign up for CMS ICD-10 Email Updates and follow us on Twitter.


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