Necessity and Implications of ICD-10:
Facts and Fallacies
Authors: Manchikanti Laxmaiah 
Published: March 2021

The International Classification of Diseases-10 (ICD-10 is a new system that is expected to be
implemented effective on October 1, 2013. This new system is a federally mandated change
affecting all payers and providers, and is expected to exceed both the Health Insurance
Portability and Accountability Act (HIPAA) and Y2K in terms of costs and risks. However,
the Administration is poised to implement these changes at a rapid pace which could be
problematic for health care in the United States.
In 2003, HIPAA named ICD-9 as the code set for supporting diagnoses and procedures in
electronic administrative transactions. However, on January 16, 2009, the Department of
Health and Human Services (HHS) published a regulation requiring the replacement of ICD9 with ICD-10 as of October 1, 2013. While ICD-9 and 10 have a similar type of hierarchy in
their structures, the ICD-10 is more complex and incorporates numerous changes. Overall,
ICD-10 contains over 141,000 codes, a whopping 712% increase over the less than 20,000
codes in ICD-9, creating enormous complexities, confusion, and expense. Multiple published
statistics illustrate that there are approximately 119 instances where a single ICD-9 code
can map to more than 100 distinct ICD-10 codes, whereas there are 255 instances where a
single ICD-9 code can map to more than 50 ICD-10 codes. To add to the confusion, there are
3,684 instances in the mapping for diseases where a single ICD-10 code can map to more
than one ICD-9 code.
Proponents of the new ICD-10 system argue that the granularity should lead to improvements
in the quality of health care, since more precise coding that more accurately reflects actual
patient conditions will permit smarter and more effective disease management in pay-forperformance programs. This, in essence, encapsulates the benefits that supporters of this
new system believe will be realized, even though many of these experts may not be involved
in actual day-to-day medical practices.
Detractors of the system see the same granularity as burdensome. The estimated cost per
physician is projected to range from $25,000 to $50,000. Further, they argue that the ICD10 classification is extremely complicated, and expensive. Concerns exist that it is being
implemented without establishing either the necessity or thinking through the unintended
consequences. Opponents also argue that beyond financial expense, it is also costly
in terms of human toll, hardware and software expenses and has the potential to delay
reimbursement. There is also concern that an unintended consequence of granularity would
be the potential for enhanced and unnecessary fraud and abuse investigations.
The authors of this article favor postponing the implementation of the ICD-10 until such time
as its necessity is proven and implications are understood.
Key words: Diagnostic coding systems, International Statistical Classification of Diseases
and Related Health Problems (ICD), ICD-9-CM, ICD-10-CM, regulations, growth, evidencebased literature, reimbursement, claims, Health Insurance Portability and Accountability Act
(HIPAA)