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Commentary: Waiting for ICD-11

In what at times feels like an unending barrage of excuses why the U.S. should further delay moving to ICD-10, one of the frequently repeated reasons is that we should wait until ICD-11 is ready for implementation.


This excuse is reminiscent of Samuel Beckett’s play Waiting for Godot:

“Let’s go.” “We can’t.” “Why not?” “We’re waiting for Godot.”

Based on the World Health Organization’s (WHO) current timeline, ICD-11 is expected to be finalized and released in 2017. For the U.S., however, that date is the beginning, not the end.  As with every WHO version of the ICD codes, ICD-11 would need to be adapted to meet the detailed payment policy, quality assessment and other regulatory requirements of U.S. stakeholders.

The modification of the WHO version of ICD-10 for use in the U.S. took eight years. It was another eleven years before the regulatory process of proposed rules and comment periods was completed and the issuance of a final rule establishing ICD-10 as the HIPAA standard code set. The ICD-10 final rule gave the industry three years to get ready for ICD-10 implementation. Two one-year delays have now pushed the time allotted for preparation to five years. Based on the ICD-10 timeline, ICD-11 would not be implemented until 2041.

It’s now 16 years since the U.S. version of ICD-10 was completed, five years since publication of the ICD-10 final rule, and the U.S. still has not implemented ICD-10. For the many healthcare organizations that worked diligently and in good faith to prepare for ICD-10, the lament in Waiting for Godot is all too true:

“Nothing happens. Nobody comes, nobody goes. It’s awful.”

The U.S. simply cannot wait decades to replace ICD-9, a code set that was developed nearly 40 years ago. U.S. healthcare data is deteriorating while at the same time demand is increasing for high-quality data to support healthcare initiatives such as the Meaningful Use EHR Incentive Program, value-based purchasing, and other initiatives aimed at improving quality and patient safety and decreasing costs.

Moreover, implementing ICD-10 is an important step on the pathway to ICD-11. ICD-11 is built on ICD-10 and benefits from the clinical knowledge and additional detail that have been incorporated into the U.S. version of ICD-10. Transitioning to ICD-10 in 2015 will provide an easier and smoother transition to ICD-11 at some point in the future.

Indeed, a 2013 report[1] on the feasibility of skipping ICD-10 and going right to ICD-11, published by the American Medical Association Board of Trustees, recommended against waiting for ICD-11 and called it fraught with pitfalls. The AMA report concluded that overall implementation and training efforts for ICD-11 will be more challenging if ICD-10 is not implemented first, and the U.S. would miss out on improvements in the ICD-10 codes that better align with today’s data needs.

Waiting for ICD-11 is simply not a viable option. The absurdity of the endless waiting in Waiting for Godot culminates in frustration:

“Let us not waste our time in idle discourse! Let us do something, while we have the chance!”

Yes, the wait needs to be over. It’s time to stop wasting time. It’s time to get ICD-10 implemented.


[1] American Medical Association. “Evaluation of ICD-11 as a New Diagnostic Coding System.” Report of the Board of Trustees. 2013.

One Comment Post a comment
  1. Dennis #

    My view on ICD-10, ICD-11 and SNOMED

    January 15, 2015

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