ICD-10-PCS stocktaking discussion at the September C&M meeting

September 18th, 2019 / By Rhonda Butler

Classification systems like ICD-10-CM and ICD-10-PCS are all about trade-offs—balancing the ongoing need for new levels of detail with the increasing complexity of the classification. PCS has its own unique bundle of trade-offs that are useful to keep in mind when evaluating proposals for changes to the system. We have a few update cycles under our belt, and we are facing the prospect of more updates under ICD-10—and likely under ICD-11 as well. (In case this is news to you, I will pass along some context for that statement—one of NCVHS’ first recommendations for moving to ICD-11 was that “HHS should clarify that ICD-10-PCS is completely separate from ICD-10 and will not be updated with the transition of ICD-10 to ICD-11.”) In other words, PCS is expected to have a very long shelf life.

The ICD-10-PCS portion of the September C&M meeting ended with something a bit out of the ordinary—an open discussion with the audience about PCS, asking what people think of how PCS has evolved based on the updates so far, and where we should be going from here. Having earned the dubious honor of participating directly in much of PCS’ history (aka “the last PCS geek standing”), CMS asked me to lead the discussion.

You can watch the discussion on CMS’ YouTube channel, beginning at 2 hours and 24 minutes into the September 10 morning session. The first ten minutes are a “why here, why now” introduction to the topic—and the discussion that follows lasts about half an hour. Rather than summarize the discussion, I invite you to listen for yourself. The discussion took several interesting turns, and after a bit of warming up people got down to saying what was really on their minds. It was refreshing to hear, because usually these occasions are carefully scripted.

There is some background material for the discussion you might also want to check out. It is included in the September C&M Agenda and Handouts on pages 48-56. There are bullet points and PCS table snippets giving a high-level review of PCS table structure, some examples of how the tables have been updated so far, areas of high demand for new procedure code detail and possibilities for future expansion.

If you want to share your thoughts on the future of PCS here on this site, that would be terrific and I’d love to hear from you. If you have comments you would like to send to CMS,  send them to ICDProcedureCodeRequest@cms.hhs.gov The comment period for the September C&M meeting ends November 8. But the discussion has only just begun, so stay tuned…

Rhonda Butler is a clinical research manager with 3M Health Information Systems.