To the Editor: The Sounding Board, entitled "Changing Diagnosis Codes," in the November 23, 1978, issue of the Journal, creates the misguided impression that problems in implementing Clinical Modification of the ninth edition of the International Classification of Diseases should be attributed to the actions (or lack of action) of the Health Care Financing Administration.It is fallacious to suggest that the delays in publication of the Clinical Modification of the ninth edition and related training and implementation activities are attributable to the Health Care Financing Administration. In contrast, publication was made possible through definitive actions taken by the . . .