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Ensure your practice is prepared to navigate annual updates
Ensure your practice is up to date with the latest changes to the ICD-10-CM coding and reporting guidelines, which take effect annually on Oct. 1. These codes are maintained by the Centers for Disease Control and Prevention’s (CDC) National Center for Health Statistics (NCHS) under the authorization of the World Health Organization (WHO) and were developed for use by the Centers for Medicare & Medicaid Services (CMS).
The AOA provides resources to help osteopathic physicians navigate updates to the ICD-10 code set, a comprehensive classification system for diagnoses, symptoms, abnormal findings and external causes of injury or disease.
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Log in to viewIn 2022, the World Health Organization (WHO) formally transitioned to the International Classification of Diseases, 11th Revision (ICD-11) code set, from ICD-10. The code set is now available for WHO member countries to adopt for recording and reporting health-related conditions. Use of standardized nomenclatures, such as ICD in diagnosis reporting is essential to healthcare operations, billing and payment and public health surveillance.
Since the first half of 2023, the AOA has been actively engaging with the National Committee on Vital Health Statistics (NCVHS) within the U.S. Department of Health and Human Services (HHS) to follow the committee’s evaluation of ICD-11 and development of recommendations regarding adoption and implementation of the code set in the U.S.
ICD-11 as a code set is fundamentally different in structure from the ICD-10-CM code set. The code set uses a foundation, or system of base codes that can be rolled up into different categories, and then a system of extension codes to create granularity. Through this system of stem and extension combinations, a coding framework that accounts for more specific diagnoses and conditions that account for over 90% of the ICD-10-CM code set can be developed.1,2 For example, ICD-11 contains a single stem code for an arm fracture which can be paired with extension codes to describe where the fracture occurred.
A recent analysis of the adequacy of ICD-11 for morbidity coding was conducted by researchers at the National Library of Medicine. Researchers performed one horizontal sample of the most commonly used ICD-10 codes and one vertical sample across the digestive diseases section of the ICD-10-CM. Key findings from this analysis were that:
The ICD-11 code set generally provides sufficient granularity to map ICD-10 to ICD-11. Further, it may allow coding for somatic dysfunction with greater detail than is currently possible. Similar to the arm fracture example noted above, this would be achieved by using the somatic dysfunction base code with extension codes for surface topography.
However, there are more than 10 surface topography extension codes (compared to the 10 body regions specified in current ICD-10 somatic dysfunction codes). Thus, when being implemented in the U.S., policymakers must define what combinations of stem and extension codes are appropriate. AOA must be closely engaged in the post-coordination process.
The process of adopting and implementing ICD-11 is highly dependent on U.S. engagement with WHO. The WHO must support any post-coordination efforts countries wish to implement and must also grant states permission if they wish to engage in clinical modification.3 Additionally, unlike ICD-10, the ICD-11 code set is designed to be updated regularly, and WHO has established a process for doing so where stakeholders can request new codes or modifications. Ultimately, the post-coordination process in the U.S. will require working with WHO to define the appropriate extensions.
Based on historical precedent, there are several critical steps that typically must be taken in order for ICD-11 to be adopted and implemented in the U.S.:
This multi-year process has not yet been initiated. Additionally, recent actions by the Trump administration, including a restructuring of the Department of Health and Human Services, as well as threats to withdraw from the World Health Organization, have created uncertainty regarding the timeline and process for a potential transition. The AOA is monitoring developments closely and will keep members updated as information becomes available.
References
CMS has released the latest updates to the ICD-10-CM code set, effective for services provided from Oct. 1, 2026, through Sept. 30, 2027. This year’s update includes: 190 new codes, four revised codes and 30 deleted codes.
The full list of changes is available via the CMS ICD-10 webpage.
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ICD-10-CM updates now in effect
The 2026 ICD-10-CM code changes are now active and must be used for all services delivered between Oct. 1, 2026, and Sept. 30, 2027. The next annual update will take effect on Oct. 1, 2027.
All HIPAA-covered entities (health plans, providers, clearinghouses) are required to use ICD-10-CM for diagnosis coding and ICD-10-PCS for inpatient procedure coding in all electronic health transactions. Plans may also require ICD-10 on paper claims for consistency.
Yes. All HIPAA-covered entities must use ICD 10 for services provided on or after Oct. 1, 2015, regardless of whether they treat Medicare or Medicaid patients.
No. ICD-10-CM/PCS are diagnosis and inpatient procedure codes. CPT codes, maintained by the AMA, continue to be used for outpatient and physician services.
Practices should focus on the codes most relevant to their specialty, ensuring documentation supports required specificity. Full mastery of all codes isn’t necessary but knowing your commonly used subsets is critical.
Somatic dysfunction codes are located in Chapter 13: Musculoskeletal System and Connective Tissue, under category M99, with subcodes from M99.00 to M99.09 indicating specific body regions.
Documentation must support the specificity required by ICD-10, detailing laterality, severity and encounter type (e.g., initial vs. subsequent). Use the ICD-10-CM Official Guidelines and ensure all descriptors are clearly documented.