Transition to the ICD-10-CM: What does it mean for psychologists?
By Practice Research and Policy staff
Update: This article has been updated to reflect the announcement from the Centers for Medicare and Medicaid Services (CMS) that the transition to ICD-10 will take place on Oct. 1, 2015, rather than Oct. 1, 2013.
Feb. 9, 2012—Beginning Oct. 1, 2015 all entities, including health care providers, covered by the Health Insurance Portability and Accountability Act (HIPAA) must convert to using the ICD-10-CM diagnosis code sets. The mandate represents a fundamental shift for many psychologists and other mental health professionals who are far more attuned to the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Disorders (DSM).
Most psychologists were trained using some version of DSM. For other health care providers, the World Health Organization’s International Classification of Diseases and Related Health Problems (ICD) – which contains a chapter on mental disorders – is the classification standard.
Over the years, efforts to harmonize these two classifications have resulted in systems with similar (often identical) codes and diagnostic names. In fact, even if psychologists record DSM diagnostic codes for billing purposes, payers recognize the codes as ICD-9-CM – the official version of ICD currently used in the United States. Since 2003, the ICD-9-CM diagnostic codes have been mandated for third-party billing and reporting by HIPAA for all electronic transactions for billing and reimbursement.
Clarifying important terms
The ICD is the global standard in diagnostic classification for health reporting and clinical applications for all medical diagnoses, including mental health and behavioral disorders. The United States will be one of the last industrialized countries to adopt the ICD-10, even though it was published in 1990. Every member state of the World Health Assembly is expected to report morbidity and mortality statistics to the World Health Organization (WHO) using the ICD codes, but countries are allowed to modify the ICD for use within their own country. Although countries are also expected to adopt the latest version of the ICD once it is approved for use, WHO cannot mandate when this will occur.
The International Classification of Diseases, Clinical Modification (ICD-9-CM or ICD-10-CM) is a modified version of the ICD created by the U.S. National Center for Health Statistics (NCHS) and Centers for Medicare and Medicaid Services (CMS). The CM versions of the ICD provide additional morbidity detail and are specifically used for medical coding and reporting in the United States.
The use of the ICD-10-CM should facilitate international data comparisons to track diseases and treatment resources. Its use may also decrease the need to include supporting documentation with claims as the ICD-10-CM codes (just as the parent ICD-10 codes) have greater specificity, such as severity indicators, within each code. The changes embodied in ICD-10-CM should result in more efficient claims management, fewer requests for clinical information and fewer rejected claims due to non-specific diagnoses.
The structure and coding for the mental and behavioral disorders classification in ICD-10-CM are different from those of the ICD-9-CM and the DSM-IV. The broad categories of mental and behavioral disorders are much the same, but the new arrangement of categories and alphanumeric codes will be different from ICD-9 and the DSM-IV codes. For instance, major depressive disorder, single episode is coded as 296.2 in both DSM-IV and ICD-9-CM but is coded as F32 in the current version of ICD-10-CM.
Where does the DSM fit in?
According to a 2009 news release from the American Psychiatric Association, the organization has worked with the Centers for Disease Control and Prevention (CDC) and CMS to develop a common structure for the DSM-IV and the mental disorders section of the ICD-10-CM. The news release also stated that they are working with WHO to link the DSM-5 with the mental and behavioral disorders section of the ICD-11, currently under development by WHO and anticipated to be released in 2014. However, given that the ICD-10-CM is now being finalized while the DSM is still undergoing revision, it is difficult to determine how closely those two classifications will correspond.
What psychologists can do to prepare for the transition
APA is developing a CE course, as well as 2012 Convention programming, to assist psychologists and other mental health providers in preparing for the ICD transition. Additionally, the APA Practice Organization will continue to monitor the revision process for both DSM and ICD and will attempt to highlight important transition points and identify valuable resources for APA members in anticipation of the Oct. 1, 2015 transition date.
CMS has launched a new website to assist providers with the transition to ICD-10. The step-by-step guides (see links below) are specifically tailored for small and medium provider practices, large provider practices and small hospitals. The guides contain information on suggested business processes, communication avenues and training, as well as potential difficulties to expect when making the transition.
What to keep in mind and expect in the future
CMS announced that there will be no grace period for the implementation of the ICD-10-CM. As of midnight on Oct. 1, 2015, any claims filed for dates of service (for providers) or discharge dates (for hospitals) on or after this date must contain ICD-10-CM codes. Because this is a HIPAA mandate, penalties for failure to comply will be enforced. Civil and criminal penalties may include heavy fines and imprisonment. For more information visit the HHS.gov HIPAA privacy rule site.
WHO will be completing the preparation of ICD-11 at about the same time that NCHS will be implementing ICD-10-CM. However, it is highly unlikely that there will be a similar delay in ICD-11 implementation in the United States.
Through a series of annual updates over the first few years following ICD-10-CM implementation, the U.S. is expected to bring ICD-10-CM in line with ICD-11, so that the latest version of the ICD can be adopted smoothly and gradually without requiring a sudden and major change in the classification or how diagnoses are reported.
American Psychiatric Association. (2009). DSM-5 Publication Date Moved to May 2013 (PDF, 54KB). New Release No. 09-65. Arlington, VA: Author.
Reed, G. M. (2010). Toward ICD-11: Improving the clinical utility of WHO's International Classification of mental disorders. Professional Psychology: Research and Practice, 41(6), 457-464.
United Health Care. (2011). Overview of HIPAA 5010 ICD-10 (PDF, 161KB).