Press Releases

Rheumatology Community Praises Rep. Diane Black for Introducing Legislation to Ensure “Fair and Responsible” Transition Into New Government Healthcare Coding System

ICD-TEN Act Calls for 18-Month “Safe Harbor” Period, Full End-to-End Testing by Centers for Medicare and Medicaid Services (CMS)

ATLANTA, Ga. – The American College of Rheumatology (ACR) today expressed its support for the ICD-TEN Act (H.R. 2247), a bill introduced by Representative Diane Black (R-TN) to ensure a reasonable and responsible transition to ICD-10. As the U.S. healthcare system transitions from the current ICD-9 medical coding set to the updated ICD-10 system, the legislation would institute an 18-month “safe harbor” period after the October 1, 2015 implementation date designed to help physicians, administrative staff and medical record management professionals effectively adapt to the sweeping healthcare coding overhaul.

The new ICD update will effectively quadruple the number of diagnosis and medical billing codes from 13,000 to more than 68,000. The transition will prove especially taxing for small and rural practices, which have fewer resources to accommodate the complexity of the new system. Under ICD-10, if physicians submit the wrong seven-digit code, they risk nonpayment altogether. Payment stability – which can be significantly altered by nonpayment due to minor coding errors – is critical to the continued delivery of quality healthcare across the nation, especially in traditionally underserved urban and rural areas.

An important provision of the ICD-TEN Act would prevent the rejection of claims and denial based solely on the use of inaccurate or unspecified sub-codes during the 18-month safe harbor period. Sub-codes do not generally specify what disease a person has, but rather what subtype or what location is affected. While this specificity is beneficial for disease surveillance and some treatment decisions, it should not affect payment. This helps ensure providers are not unfairly penalized due to minor mistakes in diagnosis coding during the transition to ICD-10. The bill does not allow dualcoding or the continued submission of ICD-9 codes.

“Our nation’s doctors and caretakers work diligently each day to help Americans tackle injury, illness, and disease,” said Rep. Diane Black, who introduced the ICD-TEN Act on May 12. “Yet even as they dedicate countless hours to people in need, we are now assigning healthcare professionals another task: learn and perfect a comprehensive medical coding system – and do so immediately when we flip the switch on October 1. I believe transitioning to ICD-10 is needed and will help improve healthcare delivery in the long run, but we must ensure the transition is as smooth as possible. An 18-month transition period allows us to innovate without putting our nation’s most vulnerable providers – and the patients who rely on their services – at risk.”

If passed into law, the ICD-TEN Act would also require that the Centers for Medicare and Medicaid Services (CMS) conduct full end-to-end testing prior to the transition and certify to Congress that the Medicare fee-for-service claims processing system based on the ICD-10 standard is fully functioning.

“As with any major technological overhaul, the transition to ICD-10 will not come without challenges. Providers across the U.S. deserve assurance from CMS that the system is fully functioning,” said Dr. William Harvey, a practicing rheumatologist and chair of the ACR Government Affairs Committee. “This assurance, along with an 18-month transition period that allows physicians and IT professionals to adjust to any initial ‘kinks’ in the system – without the threat of nonpayment looming overhead – will allow both providers and CMS to move forward with ICD-10 in a responsible way.”

“While a coding system may be out of the public spotlight, it has vast implications for physicians and the quality of care administered to our patients,” added Dr. Harvey. “A well-functioning ICD-10 system is crucial to accurate diagnosis, disease tracking, and quality improvements. And so as we embark on this transition, it is vital that we do so in a way that allows providers to continue focusing their time on patient care, while giving them a practical and clearly defined window of time to adapt to the new changes. The U.S. healthcare system has functioned on the outdated ICD-9 codes since 1979. Giving providers 18 months to transition effectively to the new code set is both fair and reasonable given the magnitude of this undertaking.”

Jocelyn Givens
404-633-3777, ext.810


The American College of Rheumatology is an international medical society representing over 9,400 rheumatologists and rheumatology health professionals with a mission to Advance Rheumatology! In doing so, the ACR offers education, research, advocacy and practice management support to help its members continue their innovative work and provide quality patient care. Rheumatologists are experts in the diagnosis, management and treatment of more than 100 different types of arthritis and rheumatic diseases. For more information, visit

© 2022 American College of Rheumatology.  All rights reserved.  Website & Privacy Policies | Sitemap | Help | Contact Us