Accurate ICD-10-CM coding requires more than selecting the best available code. It also depends on whether the classification system provides a code that adequately represents the resident’s condition. When available codes are too broad, outdated, or clinically incomplete, the resulting data may fail to reflect the resident’s true disease burden and care needs.
The American Association of Post-Acute Care Nursing (AAPACN) brings long-term care concerns into federal policy and coding discussions by identifying gaps, developing evidence-based recommendations, and amplifying members’ perspectives. This article explains how AAPACN’s advocacy helped secure three new ICD-10-CM codes for secondary malignancies of the oral cavity, larynx, and pharynx. It also briefly previews the FY 2027 ICD-10-CM update and highlights the importance of maintaining current coding resources.
Turning a Coding Concern into National Advocacy
AAPACN’s advocacy begins with the day-to-day experiences of members, identifying barriers that affect accurate resident assessment and reimbursement. Nurse assessment coordinators (NACs), coding professionals, clinicians, and other interdisciplinary team (IDT) members frequently identify situations in which existing rules or codes do not adequately represent the residents they serve.
Those concerns may first appear to be isolated coding questions. However, when the same problem affects multiple facilities or reveals a larger inconsistency within the code set, it may warrant broader review. AAPACN evaluates these concerns to determine whether they can be addressed through education, clarification from the Centers for Medicare & Medicaid Services (CMS), comments on federal rulemaking, or a formal request to revise the ICD-10-CM.
Changes to ICD-10-CM diagnoses are considered through the ICD-10 Coordination and Maintenance Committee process led by the National Center for Health Statistics and CMS. Proposals must identify the coding gap, explain its clinical significance, and recommend specific changes to the classification. The suggested changes are presented publicly and made available for stakeholder comment before federal officials determine whether to adopt them.
The Gap in Coding Secondary Head and Neck Cancers
While commenting on the Skilled Nursing Facility Prospective Payment System (SNF PPS) Proposed Rule, AAPACN repeatedly recommended that CMS recognize secondary oral and laryngeal cancers as speech language pathology (SLP) comorbidities under the Patient-Driven Payment Model (PDPM). The rationale was that only primary malignancies qualified despite the significant speech and swallowing impairments often associated with metastatic disease. CMS responded that the existing ICD-10-CM codes were too broad to support the request.
AAPACN’s review confirmed the concern. The available codes—C79.89, Secondary malignant neoplasm of other specified sites, and C78.39, Secondary malignant neoplasm of other respiratory organs—captured metastatic cancers throughout the body, making it impossible to identify secondary oral, laryngeal, or pharyngeal cancers specifically. Recognizing that the limitation existed within the ICD-10-CM classification, AAPACN developed a formal proposal requesting new site-specific diagnosis codes.
Under the federal ICD-10-CM code revision process, organizations must demonstrate a coding gap, explain its clinical significance, and present supporting evidence. Proposed revisions are evaluated on whether they improve the clinical accuracy and specificity of the classification system, not on their potential impact on reimbursement or health insurance coverage.
AAPACN Brings the Long-Term Care Perspective Forward
AAPACN formally requested the creation of unique ICD-10-CM diagnosis codes for secondary metastatic cancers of the oral cavity, larynx, and pharynx. The proposal was presented to solicit public comment during the September 2025 ICD-10 Coordination and Maintenance Committee meeting, with AAPACN identified as the requestor.
The proposal showed that the existing broad codes did not adequately identify metastatic disease involving structures critical to speech and swallowing. As a result, the coded record could not accurately communicate the resident’s condition or distinguish these malignancies for clinical analysis and healthcare data.
Consistent with the ICD-10-CM code revision process, AAPACN’s proposal focused on improving the clinical accuracy and specificity of the classification system rather than reimbursement. By requesting site-specific diagnosis codes, AAPACN sought to ensure that the coded record more accurately reflected documented metastatic disease, supporting clearer clinical communication, assessment, care planning, claims, and healthcare data (CDC, 2025).
Three New Codes for FY 2027
The final FY 2027 ICD-10-CM Tabular List includes the three codes proposed through AAPACN’s advocacy:
- C78.31, Secondary malignant neoplasm of larynx
- C78.32, Secondary malignant neoplasm of pharynx
- C79.83, Secondary malignant neoplasm of oral cavity
The codes take effect on Oct. 1, 2026.
The FY 2027 Table of Neoplasms was also revised so coders can locate the correct secondary malignancy code by site. Secondary malignancies of the larynx—including the glottis, vocal cords, subglottis, supraglottis, laryngeal cartilage, and other laryngeal structures—are redirected from C78.39 to C78.31 (CMS, 2026).
Secondary malignancies of the oral cavity and oral mucosa are redirected from C79.89 to C79.83. Secondary pharyngeal malignancies are redirected from C79.89 to C78.32 (CMS, 2026).
These changes demonstrate why annual code updates involve more than adding three codes to a diagnosis list. The Table of Neoplasms, Alphabetic Index, and Tabular List must work together to direct the user to the correct final code.
Beginning Oct. 1, facilities should review residents with active metastatic head and neck cancers to determine if they should replace an existing broad code with one of the new site-specific codes. Code assignment must be based on provider documentation identifying the secondary site. A coder must not infer metastatic involvement of the oral cavity, pharynx, or larynx solely from symptoms, treatment, or therapy documentation.
A Sneak Peek at Other FY 2027 Changes
Although the new secondary malignancy codes represent a significant advancement for long-term care, they are only one of many FY 2027 ICD-10-CM changes. This year’s update includes expanded cardiomyopathy code options, a new code for a personal history of Clostridioides difficile infection, revised instructional notes, and numerous other changes to the ICD-10-CM classification. Together, these revisions highlight the importance of reviewing the complete FY 2027 update and ensuring coding resources are current before the new codes take effect on Oct. 1, 2026.
Why Facilities Need New FY 2027 Code Books
Facilities that rely on printed ICD-10-CM manuals should order FY 2027 code books now to have them available before Oct. 1, 2026.
Using an outdated code book increases the risk of assigning deleted codes, missing new coding specificity, or overlooking revised instructional notes. Even when an electronic health record (EHR) has been updated, coders should always verify the code in the current Tabular List. Education offered annually must reinforce that a code is not final until the current Tabular List, that is, all instructional notes, exclusions, sequencing directions, and required characters, has been reviewed.
Facilities should also avoid waiting until Oct. 1 to begin implementation. The IDT should review frequently used and active diagnoses in advance, identify codes that will be deleted or expanded, and determine whether the existing documentation supports the new level of specificity. When they need clarification, they must issue a compliant provider query based on the clinical evidence in the medical record, not merely because a new code is available.
Updated coding books and electronic tools need to be paired with a coordinated implementation plan that includes the NAC, health information management or coding staff, nursing leadership, therapy, medical providers, and billing personnel. Diagnosis lists, Minimum Data Set (MDS) assessments, care plans, and claims may all be affected when an existing code changes.
Conclusion
The addition of ICD-10-CM codes C78.31, C78.32, and C79.83 confirms how member-identified challenges can lead to meaningful national change. By bringing real-world coding concerns to AAPACN, members help identify gaps in the ICD-10-CM classification system that may ultimately improve coding accuracy for providers nationwide.
As facilities prepare for the FY 2027 ICD-10-CM update, they need to acquire current coding resources, review the annual revisions, educate the IDT, and verify that active diagnoses remain accurate on and after Oct. 1, 2026. Just as importantly, members are encouraged to continue sharing coding and documentation challenges with AAPACN. Today’s question from the bedside may become tomorrow’s national coding improvement.
For more information on AAPACN advocacy, listen to the AAPACN LTC NAC Chat podcast episode: Advocacy in Action: How AAPACN Amplifies Members’ Voices. For more information on the FY 2027 ICD-10-CM coding changes, attend the AAPACN webinar: Ready, Set, Code! Preparing for the FY 2027 ICD-10-CM Updates.
Ways Members Can Share Their Voice With AAPACN
AAPACN members can share their voices and speak up about challenges in these ways:
- Ask a question or note a concern in the AAPACN Connect Community.
- Attend a webinar and ask a question during the Q&A section or attend one of the quarterly Open Q&As with AAPACN Nurse Experts webinars.
- Respond to the monthly Member Feedback Survey, found at the top of the AAPACN Leader for the NAC and Navigator for the DNS newsletters.
- Complete the AAPACN Work Study survey, sent out biannually.
- Fill out the AAPACN Conference evaluations after attending the yearly event.
- Join the AAPACN NAC-EAP or DNS-EAP.
- Ask Ava, AAPACN’s Virtual Assistant, that monitors the questions received there and notes any trends.
- Reach out directly to the AAPACN Nurse Experts.
References
Centers for Disease Control and Prevention. (2025). ICD-10 Coordination and Maintenance Committee Meeting, September 9-10, 2025, Diagnosis Agenda. https://www.cdc.gov/nchs/data/icd/September-2025-Topic-Packet.pdf
Centers for Medicare & Medicaid Services. (2026). 2027 Addendum Files (Alphabetic Index, Tabular List and Neoplasm Table). https://www.cms.gov/files/zip/2027-icd-10-addendum.zip
This AAPACN resource is copyright protected. AAPACN individual members may download or print one copy for use within their facility only. AAPACN facility organizational members have unlimited use only within facilities included in their organizational membership. Violation of AAPACN copyright may result in membership termination and loss of all AAPACN certification credentials. Learn more.