MedTech Terms
    The authoritative reference
    All terms
    ReimbursementHospital Buyer & Reimbursement

    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. ICD-10-CM is maintained in the US by CDC's National Center for Health Statistics, and ICD-10-PCS by CMS, with annual updates effective October 1. New device procedures can apply for a new PCS code through the ICD-10 Coordination and Maintenance Committee, which is often a step toward NTAP. Accurate diagnosis coding also supports medical necessity on claims.
    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

    Related terms

    Grouped by theme
    Cited by

    Where this term appears across MedTech Terms.

    Learning paths (1)

    Latest in MedTech

    Sources

    1 source

    Sources support the definition or relevant regulatory context, not necessarily every claim on this page. Each is graded against our source-tier hierarchy so you can see what rests on binding law versus commentary.

    Official citation replacements checked: . Medicare documents support Medicare coding, coverage or payment context, not every payer policy or CPT editorial procedure. Citation replacement does not change the full term review date.

    Tier 2Regulator guidance and consensus· 1
    Link health: 1 verified· last checked 2026-06-20
    1. 1
      CMS ICD-10
      Tier 2 Verified
      CMScms.gov

    Inline markers like [1] jump to the matching reference above.