NCVHS Recommends Government Actions to Prepare for US Adoption of ICD-11

By Sue Bowman, MJ, RHIA, CCS, FAHIMA

In a letter sent to the Secretary of Health and Human Services (HHS) in late 2019, the National Committee on Vital and Health Statistics (NCVHS) advised HHS to take a proactive approach toward ICD-11 and recommended several actions that should be taken now to prepare for adoption of ICD-11 in the US. The NCVHS concluded that taking a proactive approach to research, communications, and copyright for the transition to ICD-11 for mortality and morbidity classification in the US will enable the US to identify the optimal path forward, maximizing benefit and minimizing cost. Specifically, the NCVHS recommended that:

  1. HHS conduct research to evaluate the impact of different approaches to the transition and implementation of ICD-11 in the US for mortality and morbidity classification.
  2. HHS provide timely leadership on strategic outreach and communications to the US healthcare industry about the transition to ICD-11.
  3. The HHS Secretary ensure appropriate federal priority, as needed, for efforts by the National Center for Health Statistics (NCHS) to negotiate the ICD copyright issues to ensure that copyright will not be a barrier to US adoption and use of ICD-11.

While ICD-11 adoption and implementation will be a years-long process, the NCVHS is encouraging HHS to move forward with these actions to avoid a repeat of the protracted and costly transition from ICD-9-CM to ICD-10-CM/PCS. A key lesson identified by the NCVHS from the ICD-10-CM/PCS transition is that early and targeted research would have better informed the decision-making process and given stakeholders more realistic estimates of costs, benefits, public policy imperatives, and opportunities presented by ICD-10-CM/PCS. Research topics the NCVHS recommended HHS explore include:

  • The key use cases for ICD-11 for both mortality and morbidity and how well-suited ICD-11 is to support these uses.
  • Whether ICD-11 can fully support morbidity classification in the US without development of a US clinical modification (CM) and if not, are there areas to be targeted in a CM version. Development of a US clinical modification for morbidity extends the implementation timetable and requires additional ongoing processes for curation of the classification.
  • The cost and benefit estimates and opportunity costs of alternative timelines for transitioning from ICD-10 to ICD-11 for mortality and morbidity classification.
  • The impact of the changes in ICD-11’s code structure in different environments and on other health information standards designated in regulations under HIPAA or the Promoting Interoperability program.
  • The quality of World Health Organization (WHO) mappings of ICD-10 to 11 for US use cases.
  • The potential of ICD-11 to support greater convergence of clinical and administrative standards for morbidity.
  • Greater insight into how to derive benefit from the greater computer processing capability.

Specific research questions are outlined in an attachment to the NCVHS letter. The NCVHS recommended that HHS complete this research within the next 12-18 months because key questions regarding timely adoption and implementation will depend on the findings.

Another important lesson from the transition of ICD-9-CM to ICD-10-CM/PCS was that every industry stakeholder was impacted to some degree by the changes. Large-scale change requires effective communications. The NCVHS noted in its recommendation letter that a trusted source of truth for the industry would have helped to mitigate inconsistent messaging and misinformation in the protracted ICD-10-CM/PCS transition. Inadequate communication and information contributed to misperceptions of ICD-10 capabilities, limitations, costs, and benefits. A proactive and strategic approach developed in partnership with key industry organizations will help reduce the cost and burden of transitioning to ICD-11. The goal of the ICD-11 outreach and communications plan recommended by the NCVHS is to promote industry awareness and consensus-building around an optimal implementation pathway for ICD-11 for both mortality and morbidity. Key elements that should be included in the communication plan are listed in an attachment to the NCVHS letter. As with the research, NCVHS recommended that HHS develop and execute a communication plan as early as possible, preferably running parallel with the research work over the next 12-18 months.

As noted above, the NCVHS also recommended that the HHS Secretary ensure appropriate federal priorities for efforts by the NCHS to negotiate the ICD copyright issues. While the WHO has adopted ICD-11, it has not yet established copyright and use policies. Once these are established, NCHS will, as needed, negotiate an agreement on behalf of the US to ensure appropriate access to ICD-11 and subsequent updates and modification that will be released from time to time. Early research will inform a decision about whether the US will undertake a clinical modification, and thus inform NCHS negotiations.

AHIMA’s policy and government affairs team will continue to provide updates on ICD-11 transition planning and preparation activities.

Sue Bowman ( is senior director, coding policy and compliance at AHIMA.

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