Though ICD-10-PCS (procedure) codes are only required for billing purposes on inpatient claims, ICD10monitor wanted to know how many of you are using them for your outpatient claims.

For billing purposes, facilities are only required to code and submit CPT® codes for outpatient services; however, pre-ICD-10 implementation, many facilities captured both CPT and ICD-9 procedure codes for purposes other than billing.

On Sept. 1, 2015, the Talk Ten Tuesdays Internet radio broadcast produced by ICD10monitor presented a poll to see how many of our listeners were planning to code their outpatient services in ICD-10-PCS. We asked the same question on the July 19, 2016 broadcast, and the following is a comparison of the results, pre- and post- ICD-10 implementation.

What hospital outpatient services are you coding/planning to code in ICD-10-PCS?




HIM historically ICD-9 coded outpatient procedures



Outpatient surgery procedures



Observation/ED procedures



Clinic type procedures



Ancillary type procedures



Combination of the above



I don’t know what our facility is doing/not sure yet



None or not applicable



Understanding that our audience composition may have differed slightly between the two surveys, the results were somewhat similar. Overall, 37 percent of respondents in 2015 were planning to code some outpatient procedures or a combination of the outpatient procedures in PCS. In 2016, a total of 41 percent of the respondents reported that they are actually coding outpatient procedures or a combination of the outpatient procedures in ICD-10-PCS.     

Some of the reasons facilities are coding ICD-10-PCS codes for outpatient procedures are:

  1. Their states require this data.
  2. The internal quality program leverages the ICD-10-PCS codes to group inpatient and outpatient procedure data.
  3. The payer contract requires this data.
  4. The facility has always collected the ICD procedure codes for outpatient procedures.
  5. Medical registries are using ICD-10-PCS codes to compare inpatient and outpatient procedure data.
  6. It increases the flexibility of their inpatient and outpatient coding staffs.

Key reasons why some facilities are not coding ICD-10-PCS codes in addition to CPT codes with outpatient cases include:

  1. Using the additional codes decreases coder productivity.
  2. Coding CPT only maintains consistency with HIPAA and national code set regulations.
  3. Doing so decreases the number of staff members requiring ICD-10-PCS training.
  4. The data is not useful internally and not required externally.

If you are coding with ICD-10-PCS codes for outpatient visits, you should know the reason for collecting the data. HIPAA requires all outpatient procedures to be submitted using CPT/HCPCS procedure codes and ICD-10-CM diagnosis codes for billing. Unlike ICD-9-CM procedure codes, there is no official crosswalk that a coder can utilize to map the CPT/HCPCS codes to the ICD-10-PCS codes. The code assignment is a more time-consuming process for the outpatient coder if he or she is to code CPT/HCPCS and ICD-10-PCS for all procedures, in addition to the diagnosis codes. 

Need I remind everyone that we went from about 4,000 to 75,000 procedure codes when we transitioned from ICD-9-CM to ICD-10-CM/PCS? Consequently, understanding the use of the data is important.

If your facility is going to spend the extra coding resources to code all outpatient procedures in CPT/HCPCS and ICD-10-PCS, ensure that the data has a purpose.

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