Public Consultations

The Australian Consortium for Classification Development (ACCD) invited comments on various addenda proposals to improve ICD-10-AM/ACHI/ACS for the Eleventh Edition. The Public Consultation consisted of two open periods:

  • Round 1: 14 June to 28 June 2018 - closed
  • Round 2: 16 August to 30 August 2018 - closed

An overview document can be downloaded here. Link to document

All submissions received are available from this page unless respondents specifically requested that their submission be kept confidential due to commercial or other reasons. ACCD has individually responded to all feedback received. All feedback has been provided to the ICD Technical Group and the Independent Hospital Pricing Authority.

The following public consultation submissions have been received:


Person/Organisation Submission
TN94 Decreased consciousness
Kylie Holcombe, Coding Auditor, Ballarat Health Services This will be a definite improvement to the classification and its application.
TN98 Anaphylaxis
Kylie Holcombe, Coding Auditor, Ballarat Health Services These changes will be a definite improvement on how we currently code anaphylaxis particularly when related to food.
TN166 Lymph Nodes
Kylie Holcombe, Coding Auditor, Ballarat Health Services This is a good improvement to the coding of these interventions and will make it easier.
Barbara Hillier, Clinical Coder, NSW Health Excludes note for radical lobectomy 38441-00 should also be added
TN186 Allied Health Interventions
Kylie Holcombe, Coding Auditor, Ballarat Health Services

It will be good to have the code for lactation consultants, is this code for use on the mother's record only, or can it be used on the neonatal record where the mother may not be admitted?; ;

Are there any plans to have a similar code for wound care specialist and stomal therapist?

Barbara Hillier, Clinical Coder, NSW Health I think a code for Lactation Consultant is a great idea; ; I have not seen any records that include an "Exercise Physiologist"
TN693 Syndromes
Kylie Holcombe, Coding Auditor, Ballarat Health Services This will definitely make the coding of the more obscure/rare syndromes easier, a welcome change.
TN1100 Ophthalmology Part II
Lesley Ward, Clinical Coder, Tennyson Centre Day Surgery Suggest taking out the words "for glaucoma" in the tabular note associated with ACHI code 42705-00; This is in line with the concept of removing all diagnostic terms associated
TN1311 respiratory distress syndrome
Kylie Holcombe, Coding Auditor, Ballarat Health Services This is an improvement on the current classification and will allow better application of these codes.
TN1312 Nontraumatic haematoma
Kylie Holcombe, Coding Auditor, Ballarat Health Services This will be a great assistance in coding these conditions when they occur. At the moment there is no adequate way to capture nontraumatic haematomas.
ACS002 Additional diagnoses
Vedrana Savietto, Department of Health WA, Senior Coding Consultant

The section 'Commencement, alteration or adjustment of therapeutic treatment' would be clearer with addition of sub-headings: 'Transient conditions' and 'Pre-existing conditions'.; ;

An earlier version of this proposal indicated that conditions requiring mandatory code assignment (such as HIV, diabetes etc.) "may be documented by medical officers, nurses or in routine preoperative assessment by anaesthetists". This information has been removed from the current proposal. This leaves coders unable to code mandatory conditions documented by nurse alone in the current episode. Conditions such as diabetes, HIV, BMI value (obesity - supplementary chronic) are often only captured by nurses on nursing forms, particularly for same day elective admissions where the medical officer performs a procedure and does not document any comorbidities or medical history. Also, some procedures are performed without an Anaesthetist and therefore there is no Anaesthetic form detailing such comorbidities and again the information is only documented by nursing staff. These mandatory conditions are not within the scope of nursing practice, can they be coded based on nursing documentation alone?; ;

Example 2: would benefit from detailing rationale for why Alcohol dependence meets ACS 0002.; ;

Example 4: the example is too simplistic. What if after clinical review the clinician decided to continue existing treatment plan and keep dosage 20mg? According to "Commencement, alteration or adjustment of therapeutic treatment" it WOULD NOT meet criteria for coding; however following "Increased clinical care", it WOULD meet criteria for coding. I believe it should meet criteria for coding but there is conflicting instruction within ACS 0002.

Wishes to remain anonymous

All improvements to the clarity of 0002 will enhance coded data quality. Please find below some additional comments/questions:

p2 typo last sentence of ICD-10-AM,,,,,
p3 If a clinician documents a condition can a coder assume it is appropriate to their discipline?
p4 please include coding definitions of 'significant 'and 'transient'?
p4 increased clinical care and non-routine monitoring?
p5 could a coder assign nurse initiated medication if ordered by nurse practitioner/specialised nurse?
p10 Correct code assignment of additional diagnosis is very much based on variance from the norm. To ensure national consistency national education (not local) should be considered on how to identify clinical exceptions.
p12 more examples required for problems and underlying conditions. Common misconception the underlying cause needs to meet 0002

Jason Fenton, Melbourne Health, Health Information Manager, jason.fenton@mh.org,au I support the amendment of ACS 0002 that states not to assign an additional diagnosis code for a condition that is transient and can be treated successfully with administration of medication without the need for further consultation. I also support the addition to the ACS to not assign an additional diagnosis code for a condition that is treated with nurse-initiated medications, or nurse initiated interventions alone; However, I would like some clarification around assigning an additional diagnosis code for transient conditions, where clinicians prescribe items that are given as a bolus or single dose, but there is no documentation of a need for further investigation or a plan of care. These situations can include administration of electrolytes (Slow K), iron infusions (Ferrinject) and drugs such as antihistamines and anxiolytics. ; Does a written prescription in the record, signed by a medical practitioner, suffice as evidence that a consultation was performed? And thus can an additional diagnosis code be assigned for the conditions that were treated by these prescribed items?
Martin Hensher, Director – Monitoring, Reporting & Analysis, Planning, Purchasing and Performance, Department of Health, Hobart, Tasmania Tas response 11th edition ACS public consultation
TN1313 Clinical documentation, abstraction and the entire clinical record
Wishes to remain anonymous Wider private sector consultation is required on matters relating to documentation due to well-known, vast differences between private/public documentation practices/levels and not all of these are addressed in this paper or ACS. EG discharge summaries are often letters but letters are categorised in the standard as correspondence rather than summaries.
When will the clinical coding framework be available for consultation?
If a CDIS does not follow the guidelines in 0010 when obtaining clarification does this mean the information is omitted for coding purposes?
TN71 Personal history of stroke
Jason Fenton, Melbourne Health, Health Information Manager, jason.fenton@mh.org,au

Old CVA; From what I can gather this proposal is to be able to assign a code when ‘history of stroke’ is relevant to the admission. ;

I can see three scenarios:;

1. History of stroke with no residual deficits - assign the new code Z86.71 Personal history of CVA, without residual deficits.;

2. History of stroke with residual deficits - where the deficits meet criteria for coding. Assign codes for the deficits followed by I69.x Sequelae of stroke etc. This is as per the note at I69 Code first the neurological deficit and ACS 0604 Cerebrovascular accident (CVA) ….but residual deficits are still manifest and meet the criteria for an additional diagnosis.;

3. History of stroke with residual deficits - but the deficits do NOT meet the criteria for coding. Problem. Z86.71 cannot be assigned because the patient still has deficits. A code from I69.x also cannot be assigned because the deficits must first be assigned, but these can only be assigned when they meet ACS 0002 (and in this case they do not). So what is assigned?