Most of the complaints in these comments have been about diagnosis codes (ICD-10-CM) not procedure codes (ICD-10-PCS). Both ICD-10-CM and ICD-10-PCS are produc

Most of the complaints in these comments have been about diagnosis codes (ICD-10-CM) not procedure codes (ICD-10-PCS). Both ICD-10-CM and ICD-10-PCS are produced by Centers for Medicare and Medicaid Services (CMS). But ICD-10-CM is just a national version of WHO ICD-10, and as such entirely comparable to other national versions such as Australia's ICD-10-AM or Germany's ICD-10-GM. Whereas, ICD-10-PCS, despite its name, doesn't really have anything to do with WHO ICD at all, it is a purely American invention. Other countries have their own equivalents to ICD-10-PCS–for example, the Australian equivalent is ACHI (Australian Classification of Health Interventions), but unlike the US, Australia doesn't mislead people into thinking that our national procedure coding system is part of WHO ICD