The deadline for the United States to begin using Clinical Modification ICD-10-CM for diagnosis coding and Procedure Coding System ICD-10-PCS for inpatient hospital procedure coding was set at October 1, 2015,[25][26] which is a year later than a previous 2014 deadline.[27] Before that 2014 deadline, the previous deadline has been a year before that on October 1, 2013.[28][29] All HIPAA "covered entities" must make the change; a pre-requisite to ICD-10-CM is the adoption of EDI Version 5010 by January 1, 2012.[30] Enforcement of 5010 transition by the Centers for Medicare & Medicaid Services (CMS), however, was postponed by CMS until March 31, 2012, with the federal agency citing numerous factors, including slow software upgrades.[31] The implementation of ICD-10-CM has been subject to previous delays. In January 2009, the date was pushed back by two years, to October 1, 2013 rather than an earlier proposal of October 1, 2011.[32]