Preparing for October 1st and the 2018 Regulatory 1 Problem IT Import


Approximately 800 ICD-10-CM code set changes will be implemented on October 1, 2017. The 2018 Regulatory 1 Problem IT release will reflect these code set changes and is available starting August 31, 2017. IMO is committed to preparing our partners for these changes, and has provided an overview of the changes to expect in the 2018 Regulatory 1 Problem IT release. Outlined below are the IMO general recommendations along with Epic's time frame recommendations for the upcoming Problem IT release.

IMO General Recommendations

  • Clearly identify and define organizational roles and responsibilities
  • Know where to obtain download content as well as who has the ability to do so.
  • Review current organizational import and testing steps. The criticality of this step increases depending upon the time frame between IMO import loads.
  • Download the release and begin the import process when IMO releases the content on August 31 due to time sensitivity of this Regulatory release.
  • Check with organizational Epic Technical Services (TS) for the following:
    • Necessary additional content (e.g. recent SNOMED CT releases and other third-party content).
    • Assistance with post-import tasks, testing recommendations.
    • Any IMO-related SUs that you have not yet consumed and which are deemed necessary for this import.
  • Check for necessary grouper updates, such as retired or inactivated lexicals and retired ICD-10-CM codes.
    •  Review and share new calculator prompts and additional modifier selections included with the IMO Regulatory 1 release. Please see the “What’s New” tool or the IMO 2017 Modifier Roadmap (below) to review these selections.
    • Plan for inactive term review as they will require replacements on open orders.
    • Check organizational previously submitted Intelligent Service Desk (ISD) tickets that have been resolved since your last import to see which of your requests have been fulfilled.

Available Resources

Below are documents and tools to support with the IMO import and the testing process:

  • The IMO Modifier Roadmap on the Affiliate’s page of our website.
  • Interactive “What’s New” tool on the Affiliate’s page of our website. The What’s New tool is generally updated a day after Problem IT is released.
  • Contact Intelligent Service Desk (ISD) for any questions or concerns about IMO content – Customer Support will direct the inquiry to the appropriate team at IMO.
  • The 2018 ICD-10-CM Update Changes on the Affiliate’s page of our website.
  • Epic has created documentation around the 10/1 import for their customers and have delivered this to all Epic TS. Please contact your TS with Reference SLG #3275039 for more details.

The resources outlined above are beneficial to determine available modifiers, additional new terms, mapping changes, and other content changes to support October 1st implementation of ICD-10-CM.

If you are unable to access to any of the above IMO resources, please contact IMO Customer Support at or your IMO Account Manager for assistance.

Content Adjustments to Expect

The 2018 update to ICD-10-CM contains 419 new codes, 122 deleted codes, and 270 revised codes. The IMO terminologists, clinical staff, and coding professionals take a four-step approach to this update to ensure that our ICD-10-CM mappings are accurate.

1. All new and changed ICD-10-CM codes and their associated index information is reviewed to inform new Problem IT term creation and code map changes. New Problem IT terms are created to capture additional clinical detail.

2. All Problem IT terms mapped to an ICD-10-CM code impacted by the codes set changes are reviewed. If the term is mapped to deleted ICD-10-CM codes, then new ICD-10-CM mappings are assigned per the updated guidelines issued by the coding authorities.

3. Revised ICD-10-CM codes are reviewed for significant changes in meaning. If the revision is more than a re-wording of the same concept, all Problem IT terms mapped to that code are reviewed for their appropriateness based on the new meaning.

4. The ICD-10-CM review includes Problem List and Visit Diagnosis calculators as necessary to better assist with accurate levels of documentation within patient records. This review may result in additional modifier items or groups, or removals where certain coding requirements are no longer represented in ICD-10-CM.

Use of “Unspecified” Codes

Payor acceptance of "unspecified" codes and the CMS agreement expiration stating claims would not be denied as long as the coding was in the “correct family” continues to be an area of concern. IMO encourages each organization to contact insurance carriers and work with state medical associations, billing associations and health information management associations to clarify this issue (the state-run Medicaid programs, in contradistinction from Medicare, have the authority to determine rules around billing claims in their respective states). While some payors have been trying to reduce the use of unspecified codes, CMS guidelines clarify when their use may be appropriate in section I.B. 18 of this document.

“Sign/symptom and “unspecified” codes have acceptable, even necessary, uses. While specific diagnosis codes should be reported when they are supported by the available medical record documentation and clinical knowledge of the patient’s health condition, there are instances when signs/symptoms or unspecified codes are the best choices for accurately reflecting the healthcare encounter. Each healthcare encounter should be coded to the level of certainty known for that encounter.”

CMS is stating that healthcare encounters should only be documented at the level of specificity known, meaning unspecified codes are acceptable in certain circumstances. Documenting signs and symptoms when a definitive diagnosis is unable to be determined is appropriate.

IMO is currently following this CMS policy. Complete removal of unspecified codes will force documentation to specify details that are not known at the time of the encounter. For example, J18.9 (Pneumonia, unspecified organism) is an important and commonly recorded diagnosis in both the ambulatory and Emergency Department settings, as the bacterial or viral cause is often unknown at the time of diagnosis with bacterial cultures taking two to three days to process. IMO also encourages provider education around the need to fully specify a diagnosis wherever it is possible, particularly with simply coding in the right "family" of codes no longer being sufficient.

Overall, IMO continues to monitor CMS’s handling of unspecified codes. IMO and Epic have discussed this issue and fully recognize its complexity. IMO has gathered feedback and connected teams at Epic with customers who have expressed a desire to improve transparency around the selection of terms mapped to “unspecified” ICD-10-CM codes. Please speak with the organizational Epic TS about any concerns regarding provider selection of terms mapped to “unspecified” ICD-10-CM codes for further guidance to the most appropriate Epic resource to assist in this area.

Other Updates

Recently, SNOMED International and the National Library of Medicine released the 2017 July SNOMED CT International update. This version of SNOMED CT will be compatible with the 2018 Regulatory 1 update of Problem IT.

IMO has issued the Modifier Roadmap for 2017-2018 cycle, which outlines the planned expansion of calculator content over the next year. These roadmaps provide a useful reference for upcoming content expansions. IMO welcomes feedback on upcoming development and prioritization of new modifiers.


IMO is hosting informational webinars on a number of topics related to the Problem IT 2018 Regulatory 1 update. These webinars also provide an important place to hear customer feedback. Please watch for invitations to these webinars shortly!

Epic’s Recommended Timeline for a Successful Regulatory Import


Date Step
09/01 Download 2018 Regulatory 1 and all other necessary content
09/01-09/08 Complete diagnosis import into POC
09/08-09/21 Complete post-import tasks and validation
09/21-09/23 Migrate content into TST
09/23-09/30 Complete diagnosis content testing
09/30-10/01 Migrate content into PRD


Have Questions or Need Help?

As a general rule of thumb, questions about content (terms, mappings, modifiers, etc.) should be directed to IMO, and questions about import steps or testing processes should be directed to Epic. If unsure, contact both IMO and Epic in order to get the assistance as soon as possible. Collaboration between IMO and Epic increases during this time to ensure a smooth transition for all of our customers.


IMO values ALL feedback. Reply to this email or write to

IMO Problem IT Team