In our February 2009 Employee Benefits Update, we reported that HHS had finalized updated code sets and standards for electronic data interchange. The final regulations require covered entities to use the Tenth Revision of the International Classification of Diseases (ICD-10) code set to report healthcare diagnoses and inpatient hospital procedures. The final updates to the electronic transaction standards are required to support the new code sets and contain structural and technical improvements.  

Compliance with the updated electronic transaction standards is required by January 1, 2012 (small health plans have until January 1, 2013 to comply with the new standard for Medicaid pharmacy subrogation transactions). All covered entities, including small health plans, must be using the new ICD-10 code sets by October 1, 2013.