Background 

Traditionally, the International Classification of Diseases, Tenth Revision (ICD-10) Coordination & Maintenance (C&M) Committee meetings are held each spring and fall. The Centers for Medicare & Medicaid Services (CMS) typically leads discussion on revisions to the ICD-10-Procedure Coding System (PCS) code set, while the US Centers for Disease Control and Prevention’s (CDC) National Center for Health Statistics (NCHS) leads discussions on the ICD-10-Clinical Modification (CM) diagnosis code set. Each agency is responsible for maintaining its respective code set. 

In 2025, this format shifted. The spring 2025 meeting was closed to the public. CMS held a private meeting to discuss ICD-10-PCS and NCHS did not meet to discuss ICD-10-CM revisions. Conversely, at this fall meeting, CMS did not participate to discuss ICD-10-PCS revisions. CMS again held a closed meeting. This separation marked a departure from the usual joint participation model. 

The fall meeting remained an open forum for reviewing ICD-10-CM proposals, with public input encouraged both during the sessions and through written comments afterward. Any approved code changes will take effect on either April 1, 2026, or October 1, 2026. The C&M Committee meetings continue to be an open forum to discuss proposals for revisions to the ICD-10-CM code set and are an invaluable opportunity to be abreast of and participate in the future shaping of this code set. 

Summary of Proposed Changes 

The latest ICD-10-CM proposals introduce new codes spanning key disease areas, including amyloid-related imaging abnormalities in Alzheimer’s disease (AD), biomarker-based AD diagnostics, early diabetes screening, post-bariatric hypoglycemia, obesity associated with MC4R pathway disruption, metabolic dysfunction with alcohol-associated liver disease, and cancer risk stratification. These updates aim to enhance diagnostic precision, improve population-level surveillance, and reduce misclassification across conditions with significant clinical and public health impact. Proposals reflect both emerging science—such as blood-based biomarkers for AD and genetic insights into obesity—and evolving clinical practices like presymptomatic diabetes screening.  

Implementation of Proposed Changes 

Public comments are due by October 10, 2025, for codes being considered for an April 1, 2026, implementation and November 14, 2025, for codes being considered for an October 1, 2026, implementation. Codes finalized after the public comment period will be included in Table 6A of the Fiscal Year 2027 Inpatient Prospective Payment System Proposed Rule, which CMS is expected to release around April 2026. Codes not finalized may be discussed again during the March 2026 ICD-10 C&M Committee meeting.   

December 5, 2025, is the deadline for the public to submit a request to have topics discussed at the spring 2026 ICD-10 C&M Committee meeting on March 17-18. Diagnosis code requests should be directed to NCHS as historically outlined. During the September meeting, moderators announced that there will be new guidance on the ICD-10-CM Proposal Process for diagnosis-related proposal submissions that will be announced mid-October. For an exclusive on discussion details and strategic support, reach out to Pam Gorman at pamela.gortman@avalerehealth.com. 

Stakeholder Impacts of New Codes 

The introduction of new ICD-10-CM codes can have various impacts on stakeholders across the healthcare system: 

• Manufacturers: Must adjust market access and reimbursement strategies to align with new codes and shifting demand. 

• Providers: Need to update diagnosis and billing practices, with possible training and electronic health record adjustments affecting workflows, prior authorizations, and reimbursement. 

• Health Plans: May revise medical necessity logic, coverage, and rates, impacting cost management and actuarial planning. 

• Patients: Could see changes in access, treatment options, and out-of-pocket costs depending on coverage shifts. 

• Policymakers: Can leverage updated coding data for surveillance, resource allocation, and policy development. 

Partner With Us 

Avalere Health brings deep coding, clinical, and market expertise to help manufacturers navigate strategic code applications and translate reimbursement strategies into improved patient access. Our team actively monitors coding developments—regularly attending CMS and CDC meetings—to capture real-time insights and anticipate shifts in the reimbursement landscape. By staying ahead of these changes, we partner with life sciences companies to enhance patient access and health outcomes. To learn more about how Avalere Health can assist you, please connect with us.