Update on proposal to add DSM-5’s Somatic symptom disorder to ICD-10-CM

Post #302 Shortlink: http://wp.me/pKrrB-3PE

Update at April 5, 2014: Implementation of the U.S.’s forthcoming adaptation of ICD-10, ICD-10-CM, has been kicked further down the road to no earlier than October 1, 2015.

Bill H.R. 4302, known as the PAM Act (Protecting Access to Medicare Act), was signed into law by President Obama on April 1, 2014. This means that the U.S. cannot now transition from ICD-9-CM to ICD-10-CM on October 1, 2014. CMS has yet to issue a full statement, update its webpages and issue guidelines for a new implementation date. No statement has yet been made concerning the impact of this legislation on the timeline for the ICD-10-CM update process during a partial code freeze.

Update at April 5, 2014: The Summary of the March 19–20, 2014 meeting of the ICD-10-CM/PCS Coordination and Maintenance Committee meeting has now been posted http://www.cdc.gov/nchs/data/icd/Summary_March_2014.pdf

Lots of “outrage” over SSD and DSM-5 but I see little evidence of sustained “outrage” over proposals to add SSD as an Inclusion term to the U.S.’s ICD-10-CM.

If NCHS rubber stamps the addition of Somatic Symptom Disorder to ICD-10-CM it could leverage the future replacement of the existing Somatoform disorders categories with this new, poorly validated single SSD diagnostic construct, bringing ICD-10-CM in line with DSM-5.

There are implications for ICD-11, too.

Once SSD is inserted into ICD-10-CM, the presence of this term within the U.S. adaptation of ICD-10 may make it easier for ICD-11 Revision Steering Group to justify proposals to replace the existing ICD-10 Somatoform disorders categories with a single, new ICD construct contrived to incorporate SSD-like characteristics and facilitate harmonization between ICD-11 and DSM-5 disorder terms and diagnostic criteria.

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This post updates on proposals at the March meeting of the ICD-10-CM/PCS Coordination and Maintenance Committee to add DSM-5’s controversial new Somatic symptom disorder as an Inclusion term to ICD-10-CM.

But first, a necessary recap of the September 2013 meeting:

ICD-10-CM/PCS Coordination and Maintenance Committee meetings provide a public forum to discuss proposed changes to the U.S.’s forthcoming ICD-10-CM and ICD-10-PCS, scheduled for implementation on October 1, 2014 to be confirmed.

The public meetings, which are co-chaired by representatives for CMS and NCHS, take place in March and September and are followed by public comment periods.

The fall meeting of the ICD-10-CM/PCS Coordination and Maintenance Committee was held on September 18–19, 2013.

On Day Two of the September meeting, American Psychiatric Association’s Darrel Regier, MD, had proposed six new DSM-5 disorders for inclusion in ICD-10-CM.

On Page 45 and 46 of the Diagnosis Agenda, under Additional Tabular List Inclusion Terms for ICD-10-CM, a number of other changes to specific Chapter 5 F codes had also been proposed. These were introduced en masse, by CDC’s Donna Picket. (Reached on Day Two, at 1:22:21 in from the start of Videocast Four.)

This section of the Diagnosis Agenda included the proposals to add the new DSM-5 disorders: Somatic symptom disorder (proposed to Add as an Inclusion term to F45.1 Undifferentiated somatoform disorder) and Illness anxiety disorder (proposed to Add as Inclusion term to F45.21 Hypochondriasis) to ICD-10-CM’s Chapter 5 codes.

(F45.1 and F45.21 are the ICD-10-CM codes to which these two new APA disorders are already cross-walked in the DSM-5.)

Source: Page 45, Diagnosis Agenda (Topic Packet), September 18–19, 2013 ICD-10-CM/PCS Coordination and Maintenance Committee Meeting

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Videocasts of the entire September 2013 meeting proceedings, Diagnosis Agenda (Topic Packet), Procedural Agenda, Meeting materials etc can be found in Dx Revision Watch Post #277.

Note: there was no proposal at the September 2013 meeting to create a unique code for either Somatic symptom disorder (SSD) or Illness anxiety disorder, for either 2014 or October 1, 2015 implementation, and no proposal that Somatic symptom disorder should replace or subsume any of the existing ICD-10-CM F45.x Somatoform disorders. Note also, these proposals are specific to the forthcoming U.S. clinical modification of ICD-10.

In relation to the section of the Agenda on Pages 45 and 46, CDC’s, Donna Picket, had stated:

1:22:21 in: Diagnosis Agenda: “Additional Tabular List Inclusion Terms for ICD-10-CM”

Donna Pickett (CDC): “…And just to complete the package, there are other Tabular List proposals that appear on Page 45 and 46 that we would also invite your comments on. And again, with some of the terminology changes that Dr Regier has described the intent here is to make sure that if those terms are being used, that they do have a home somewhere within ICD-10-CM to facilitate people looking these up. So we invite comments. We’re showing the Tabular List proposed changes; however, there obviously would be associated Alphabetic Index changes with that which we didn’t show just to keep the package a little bit smaller…”

Source: [Unofficial transcription from Video Four, September 2013 ICD-9-CM C & M Committee meeting.]

There were no questions or comments from the floor or by phone link on any of the proposals listed on Pages 45 and 46 under “Additional Tabular List Inclusion Terms for ICD-10-CM” and no discussion or queries on any of the individual proposals listed under under this section of the Agenda between the meeting co-chairs and APA’s, Dr Regier.

NCHS’s decision on proposals to add Somatic symptom disorder (SSD) and Illness anxiety disorder as Inclusion terms to ICD-10-CM Tabular List Chapter 5, and to also add to the Index, isn’t known and may not be evident until the next ICD-10-CM Addenda is released, later this year, or until the Final Addenda released.

Some of the objections that were submitted last year to the proposal to add Somatic symptom disorder (SSD) as an Inclusion term in ICD-10-CM at the September 2013 meeting are collated on Dx Revision Watch here.

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March 2014 meeting of the ICD-10-CM/PCS Coordination and Maintenance Committee

This meeting took place on March 19–20, 2014. I was unable to attend as I live in the UK.

The ICD-9-CM and ICD-10-CM Timeline and Diagnosis and Procedure Codes Agenda (Topic Packet) can be found here, on the CDC website:

Proposals (Topic Packet) March 19-20, 2014

Procedure Agenda, Meeting Materials and Handouts can be downloaded from Zip files here, on the CMS website:

Meeting Materials March 19-20, 2014

A Summary Report of the Diagnosis part of the meeting is scheduled to be posted on the NCHS website, in June.

A Summary Report of the Procedure part of the meeting is scheduled to be posted on the CMS website, in June.

April 17, 2014: Deadline for receipt of public comments on proposed procedure code revisions discussed at the March 19, 2014 ICD-10 Coordination and Maintenance Committee meeting for implementation on October 1, 2014.

June 20, 2014: Deadline for receipt of public comments on proposed code revisions discussed at the March 19–20 meeting for implementation on October 1, 2015.

ICD-10-CM is currently subject to a partial code freeze. During the freeze, the public will be asked to comment on whether or not a proposal should be approved, and if not, why; and whether requests for new diagnosis or procedure codes should be created based on the criteria of the need to capture a new technology or disease. Any code requests that do not meet the criteria will be evaluated for implementation within ICD-10-CM on and after October 1, 2015 to be confirmed once the partial freeze has lifted.

Comments on the diagnosis proposals presented at the ICD Coordination and Maintenance Committee meeting should be sent, preferably by email, to the following address by June 20th deadline: nchsicd9CM@cdc.gov

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The Two Day proceedings were streamed live and can be watched on YouTube:

Video One: Day One: Morning Session: Procedural Codes: 2014 Mar 19th, FY 2014 ICD-10 Coordination and Maintenance Committee

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Video Two: Day One: Afternoon Session: Procedural Codes: 2014 Mar 19th, FY 2014 ICD-10 Coordination and Maintenance Committee

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Video Three: Day Two: Diagnosis Codes: 2014 Mar 20th, FY 2014 ICD-10 Coordination and Maintenance Committee

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Page 64, Topic Packet: http://www.cdc.gov/nchs/data/icd/Topic_packet_3_19_2014.pdf

[Extract]

Chapter 5 Addenda

The American Psychiatric Association (APA) proposes the following addenda changes to the ICD-10-CM Tabular and Index, specifically to Chapter 5, Mental, Behavioral and Neurodevelopmental disorders (F01-F99).

The APA indicates that these revisions are necessary because DSM-5 contains several new diagnoses, as well as new disorder titles, that do not map well to any existing ICD-10-CM codes.

Because of this, they are proposing numerous new index entries and tabular inclusion terms to ensure that coders can correctly identify the codes to use. The APA proposes that these changes will also ensure that new DSM-5 disorder titles correspond to a valid ICD-10-CM code.

Many of the changes in the proposed addenda relate to the reconceptualization of the substance use disorders from having separate disorder names and codes for substance abuse and dependence. However, extensive scientific evidence was assembled to show that, rather than existing as two separate disorders, these conditions exist on a spectrum that the APA has now conceptualized as ranging from mild to moderate to severe. In order to make the closest approximations with existing ICD-10-CM codes, it is noted that codes for mild substance use disorders correspond to the abuse codes and codes for moderate and severe substance use disorders correspond to dependence codes. The APA may recommend changes in the structure and names of ICD-10-CM substance related disorders, in the future, however at the present time they are only recommending the addition of the new terminology as inclusion terms.

The following addenda are proposed for implementation on October 1, 2015

[…]

1:12:12 in from start of YouTube Three: Chapter 5 Addenda Proposed Tabular Modifications.

1:12:12 Beth Fisher (CMS): Introduces proposals for [Tabular] modifications from APA for Chapter 5. These are all Addenda type changes because [ICD-10-CM is] in code freeze mode, we didn’t have the opportunity to do new codes just yet. Hands podium to Darrel Regier, MD.

1:13:01 Darrel Regier (APA): Mapping DSM-5 to ICD-10-CM codes; Major change to rename Dementias group to Major Neurocognitive Disorders, because including in this group some neurocognitive deficit conditions such as Traumatic brain injury and other neurocognitive disorders that are not inherently some of the neurodegenerative diseases, such as Alzheimer’s, Picks Disease. (Page 64 Diagnosis Agenda)

1:14:02 Darrel Regier (APA): We’ve also introduced [in DSM-5] a Mild neurocognitive disorder that reflects the Mild cognitive impairment, MCI, that is currently in ICD-9, ICD-10…

1:15:06 Darrel Regier (APA): A lot of significant changes to substance abuse disorder area which will require some notes and guidelines…

1:15:27 Darrel Regier (APA): [APA has] a number of new disorders…15 new disorders that are in the DSM-5, but there were 50 disorders that were actually subsumed into a spectrum of conditions that dropped the total number of disorders by something like 28; so you had 50 disorders that collapsed into 22 disorders. Among those, some of the most prominent – Aspergers, Autism, Pervasive developmental disorder NOS, into a single Autism spectrum disorder…assessed on two domains…assessed in terms of level of severity instead of categorical distinctions…

1:17:04 Darrel Regier (APA): Eliminating distinction between abuse and dependence so that on a continuum of Mild, Moderate, Severe…no strict separation between abuse category and dependence…

1:21:00: Question from floor re Alcohol abuse, Alcohol dependence.

1:31:15 Beth Fisher (CDC): Some of these Inclusion terms may have been proposed at September 2013 meeting. (But does not explain the reason for their being resubmitted at the March meeting.)

1:31:34 Beth Fisher (CDC): Begins running through all Addenda Additions.

1:31:42 Beth Fisher (CDC): At F44 Dissociative and conversion disorders, Add Conversion disorder, in parenthesis, functional neurological symptom disorder as Inclusion term.

Source: ICD-10-CM C & M Committee meeting, March 20, 2014, Screenshot Video Three

Note, there was no proposal under these Proposed Tabular Modifications to Add Somatic symptom disorder as Inclusion term to F45.1 Undifferentiated somatoform disorder to the Tabular List. But the proposal to Add Somatic symptom disorder as an Inclusion term to F45.1 Undifferentiated somatoform disorder to the Tabular List and to the Alphabetical Index had been proposed at the September 2013 meeting.

Also, no proposal to Add Illness anxiety disorder to the Tabular List, but again, this had been proposed at the September 2013 meeting (under F45.21), for both the Tabular List and the Index. (Decisions on all four of these September 2013 meeting proposals are unknown.)

1:34:06 Beth Fisher (CMS): Concludes proposed Addenda Additions to Chapter 5 Tabular List.

1:34:12 Beth Fisher (CMS) Moves onto Proposed Index Modifications from Page 82, Topic Packet.

1:42:36 Beth Fisher (CMS) Page 89: [Under main Index term “Disorder”] And then Somatic symptom disorder to F45.1.

Page 89, Diagnosis Agenda Add Somatic symptom disorder

Source: ICD-10-CM C & M Committee meeting, March 20, 2014, Screenshot Video Three

(No comments from floor regarding proposal to Add SSD to Index, or queries in respect of outcome of September meeting proposals. It was not feasible for me to participate in this meeting via phone link from UK to query.)

Note, there was no proposal under Proposed Index Modifications to add Illness anxiety disorder to the Index, but this proposal had been included in the September 2013 Topic Packet. Why SSD has been resubmitted for consideration for addition to the Index at the March 2014 meeting is unclear, and as I say, the outcome of proposals for the September meeting for both SSD and IAD to be added to both Tabular List and to Index is unknown.

1:44:25 Beth Fisher (CMS): Concludes proposed Addenda Additions to Chapter 5 Alphabetical Index. Invites comments.

1:44:26: Questions from floor regarding Alcohol; Cannabis; Cocaine use; Implications for legal differences between states for use of cannabis. Question regarding Neurodegeneration due to alcohol.

1:50.02 Beth Fisher (CMS): Other Addenda (Ed: presumably Tab and Index Addenda on pp 91–93 and 93–97) were reached on Day One, as there was time, so not being presenting on Day Two. Invites further comments.

1:50.27 Donna Picket (CDC): Adjourns meeting. Reminds floor (and participants via phone link/videocasts and non attendees), to submit comments on Diagnosis proposals by June 20 deadline.

1:51:07 Question from floor: Process question: if these proposals are all approved, when will they be approved and when will they be effective, because we want to notify our members of what codes to use?

1:51:32: Donna Pickett (CDC): All of these being presented were for consideration for implementation in October 1, 2015. Within 2015, we have a huge body of work that has been accumulating during partial code freeze and we’ve encouraged comments to come in about the timing for making the Final Addenda available. The typical time frame we have used in the past is posting [Addenda] in June and proposals to become effective October 1, of that same year. However, issues have arisen because there is a huge body of work and it was mentioned, yesterday, [during Meeting Day One] that the industry may want to have an Addenda released earlier and we invited comment on that, because of the amount of work that would need to go into incorporating the changes into the relevant systems and programs etc. If we were to stay with the traditional process, the Addenda would be made available in June. Meeting concluded.

Comments on the diagnosis proposals presented at the ICD-10-CM Coordination and Maintenance Committee meeting should be sent, preferably by email, to the following address by June 20th deadline: nchsicd9CM@cdc.gov