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    ICD-10-CM / ICD-10-PCS

    Diagnosis (CM) and inpatient procedure (PCS) coding systems used in U.S. claims.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed May 5, 2026

    Definition

    ICD-10-CM codes are diagnosis codes used across all care settings; ICD-10-PCS codes describe inpatient procedures and drive MS-DRG assignment for hospital reimbursement.
    What the regulation says
    ICD-10-CM codes are used for reporting diagnoses across all healthcare settings, as mandated by the Health Insurance Portability and Accountability Act (HIPAA) for electronic transactions. ICD-10-PCS codes are specifically for reporting inpatient procedures and are critical for reimbursement under systems like Medicare Severity-Diagnostic Related Groups (MS-DRGs) in the United States, as managed by the Centers for Medicare and Medicaid Services (CMS). The correct application of these codes directly impacts billing, data collection, and public health reporting.

    What this means in practice

    Securing a unique ICD-10-PCS code can materially change inpatient payment for a new procedure or device. CMS holds public ICD-10 Coordination & Maintenance meetings twice yearly.

    Examples

    • A MedTech manufacturer develops a novel surgical implant; they must ensure that a corresponding ICD-10-PCS code exists or is proposed to ensure hospitals can bill for its use effectively.
    • A regulatory affairs specialist reviews clinical study data to identify diagnoses that will be reported using ICD-10-CM codes, verifying alignment with the intended use and claims for the device.
    • During post-market surveillance, ICD-10-CM codes associated with device complications or adverse events are analyzed to identify potential trends or issues.
    Common pitfalls
    • •Assuming that a MedTech product automatically receives a unique ICD-10-PCS code without active engagement in the CMS coordination and maintenance process is a common mistake.
    • •Failing to understand the specific criteria and timelines for proposing new ICD-10 codes can lead to delayed market access or suboptimal reimbursement for new technologies.
    • •Incorrectly coding diagnoses (ICD-10-CM) or procedures (ICD-10-PCS) can result in claim denials, audits, and potential penalties.
    • •Overlooking the distinction between ICD-10-CM for diagnoses and ICD-10-PCS for inpatient procedures can lead to mischaracterization of a device’s impact or use.

    Frequently asked questions

    Regulatory professionals monitor the development of new ICD-10 codes, particularly ICD-10-PCS, to ensure that their MedTech products can be appropriately coded for reimbursement and data tracking. They may engage in the CMS coordination and maintenance process to advocate for new codes relevant to their devices.

    Cross-references

    See also

    Closely related context worth reading.

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    Primary references

    3 sources
    Link health: 3 verified· last checked 2026-06-20
    CMS·1AMA·1AdvaMed·1
    1. 1
      CMS ICD-10
      Verified
      CMScms.gov
    2. 2
      AMA CPT Resources
      Verified
      AMAama-assn.org
    3. 3
      AdvaMed - Payment & Coverage
      Verified
      AdvaMedadvamed.org

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