CMS expected to announce proposal for new ICD-10 implementation date sometime in April

CMS expected to announce proposal for new ICD-10 implementation date sometime in April

Post #153 Shortlink: http://wp.me/pKrrB-218

In a press release on February 16, Health and Human Services Secretary, Kathleen G. Sebelius, announced HHS’s intent to initiate a process to postpone the date by which certain health care entities have to comply with ICD-10-CM diagnosis and procedure codes.

The final rule adopting ICD-10-CM as a standard was published in January 2009, when a compliance date of October 1, 2013 had been set – a delay of two years from the compliance date initially specified in the 2008 proposed rule.

Several sites covering CMS’s intention to delay implementation are citing April as the month in which a new timeline for ICD-10-CM is expected to be announced:

HC Pro

New ICD-10 implementation date expected in April

ICD-10 Trainer | March 21, 2012

CMS plans to announce a new ICD-10 implementation date sometime in April, according to representatives of CMS and MassHealth, a public health insurance program for low and medium-income residents in Massachusetts.

Renee Washington, director of customer system integration at MassHealth, revealed the time frame for the much anticipated announcement during the Massachusetts Health Data Consortium’s March 9 conference call. Renee Richard from the CMS Regional Office in Boston confirmed this information during the call…

HC Pro Just Coding

Healthcare News: CMS targets April for release of new ICD-10-CM/PCS implementation date

March 20, 2012

CMS expects to release a new ICD-10-CM/PCS implementation date sometime in April. That date will be the same for payers and providers. (Excerpt from a member only article.)

ICD-10 Watch (no connection with this site which was formerly known as “DSM-5 and ICD-11 Watch”)

It’s about time for an ICD-10 delay announcement

Carl Natale | March 30, 2012

It looks like next week is when the Centers for Medicare and Medicaid (CMS) will announce their proposals for a new ICD-10 timeline.

Which should mean they will publish it in the Federal Register and take public comment for 60 days. Then they will consider the feedback and issue a final rule. Who knows when that will be…

Read full round up by Carl Natale

 

Christopher Chute, MD, (Chair, ICD-11 Revision Steering Group) et al set out the case for delaying implementation, in this paper published at Health Affairs:

Health Affairs

At the Intersection of Health, Health Care, and Policy

There Are Important Reasons For Delaying Implementation Of The New ICD-10 Coding System

Abstract: http://content.healthaffairs.org/content/early/2012/03/21/hlthaff.2011.1258.abstract

Full free text: http://content.healthaffairs.org/content/early/2012/03/21/hlthaff.2011.1258.full

PDF: http://content.healthaffairs.org/content/early/2012/03/21/hlthaff.2011.1258.full.pdf+html

Published online before print March 2012, doi: Health Aff March 2012 10.1377/hlthaff.2011.1258

There Are Important Reasons For Delaying Implementation Of The New ICD-10 Coding System

Christopher G. Chute 1,*, Stanley M. Huff 2, James A. Ferguson 3, James M. Walker 4 and John D. Halamka 5

Author Affiliations

1 Christopher G. Chute (chute@mayo.edu) is a professor of biomedical informatics at Mayo Clinic, in Rochester, Minnesota.
2 Stanley M. Huff is a professor of biomedical informatics at the University of Utah, in [please provide city], and chief medical informatics officer at Intermountain Healthcare, in Murray, Utah.
3 James A. Ferguson is a fellow at the Kaiser Permanente Institute for Health Policy and vice president of health information technology strategy and policy for Kaiser Permanente, in Oakland, California.
4 James M. Walker is chief health information officer of Geisinger Health System, in Danville, Pennsylvania.
5 John D. Halamka is a professor of medicine at Harvard Medical School, chief information officer at Beth Israel Deaconess Medical Center, and chief information officer at Harvard Medical School, in Boston, Massachusetts.
*Corresponding author

Abstract

Federal authorities have recently signaled that they would consider delaying some aspects of implementation of the newest version of the International Classification of Diseases, known as ICD-10-CM, a coding system used to define health care charges and diagnoses. Some industry groups have reacted with dismay, and many providers with relief. We are concerned that adopting this new classification system for reimbursement will be disruptive and costly and will offer no material improvement over the current system. Because the health care community is also working to integrate health information technology and federal meaningful-use specifications that require the adoption of other complex coding standardization systems (such as the system called SNOMED CT), we recommend that the Centers for Medicare and Medicaid Services consider delaying the adoption of ICD-10-CM. Policy makers should also begin planning now for ways to make the coming transition to ICD-11 as tolerable as possible for the health care and payment community.

Full free text

Tom Sullivan, for Health Care IT News, asks Chute, “Why not just skip right to ICD-11?”

Why not just skip right to ICD-11?

Tom Sullivan, Government Health IT| March 13, 2012

…While industry associations battle over the code set’s future, and HHS figures out when the new compliance deadline will be, the World Health Organization (WHO) is already moving toward ICD-11, promising a beta in 2014 to be followed by the final version in 2015. Should that slip until 2016, U.S. health entities will still be settling into ICD-10 when ICD-11 arrives – meaning that shortly thereafter, we will be right back where we are now: Behind the times, on the previous ICD incarnation.

Are we repeating our own faulty history?

“That almost assuredly will be the case,” said Chris Chute, MD, DrPH, who spearheads the Mayo Clinic’s bioinformatics division and chairs the WHO’s ICD-11 Revision Steering Group…

Read full article by Tom Sullivan

Rhonda Butler argues why US health care providers and industry can’t just ditch ICD-10-CM and wait for ICD-11 in 2015/16:

3M Health Information

We Can’t Skip ICD-10 and Go Straight to ICD-11

Rhonda Butler | March 26, 2012

Since the recent announcement by CMS that ICD-10 implementation will be delayed for certain healthcare entities, some industry pundits have argued, “Let’s just skip ICD-10 and go straight to ICD-11.”

Skipping ICD-10 assumes that we haven’t started implementing ICD-10. Well, the U.S. did start—19 years ago.

What have we been doing for the last 19 years…

Read full article

Letter from Justine M. Carr, MD, Chairperson, National Committee on Vital and Health Statistics to The Honorable Kathleen Sebelius, Secretary, Department of Health and Human Services, March 2, 2012

Contains ICD-10-CM timeline

    Re: Possible Delay of Deadline for Implementation of ICD-10 Code Sets

James Phillips asks Michael First (Editor of DSM-IV-TR, Consultant to WHO ICD-11 Revision) how DSM-5 relates to ICD:

Psychiatric Times

DSM-5 In the Homestretch—1. Integrating the Coding Systems

James Phillips, MD | 07 March 2012

With DSM-5 scheduled for publication a little more than a year from now, we may safely assume that, barring unannounced surprises from, say, the APA Scientific Review Committee, what we will see on the DSM-5 Web site is what we will get. With that in mind it’s time to review what we will indeed get. But before moving to significant changes in the major disorder categories, we should remind ourselves where DSM-5 fits into the larger picture of coding mental illnesses.

There are, in case you have forgotten, two classificatory systems of mental disorders—the International Classification of Diseases (ICD), produced by the World Health Organization (WHO), and the Diagnostic and Statistical Manual (DSM), produced by the American Psychiatric Association. How are they related? It is a question that has confused me, and I assume, some of my psychiatric colleagues as well as others—other mental health professionals, and still others. For an answer to this question I asked Michael First, MD, Editor of DSM-IV-TR, Consultant on the WHO ICD-11 revision…

Read full commentary

 

Related posts:

HHS Secretary Sebelius announces intent to delay ICD-10-CM compliance date  February 16, 2012

AHIMA: Ten Reasons to Not Delay ICD-10 (ICD-10-CM)  February 23, 2012

HHS Secretary Sebelius announces intent to delay ICD-10-CM compliance date

HHS Secretary Sebelius announces intent to delay ICD-10-CM compliance date

Post #142 Shortlink: http://wp.me/pKrrB-1Ux

Coverage today of the announcement by Health and Human Services (HHS) Secretary Kathleen G. Sebelius of intent to delay ICD-10-CM compliance date.

Will American Psychiatric Association Board of Trustees take this opportunity to delay its DSM-5 timeline, take a breathing space, and reconsider its controversial proposals for DSM-5, or submit them to independent scientific scrutiny?

Link to report at end of post also quotes Chris Chute, Chair, ICD-11 Revision Steering Group, on possible delay for completion of ICD-11 from 2015 to 2016 – no surprise that ICD Revision may be considering another shift of timeline given the technical ambitiousness of the revision project, the lack of resources and slipping targets for the Alpha and Beta drafts.

Tom Sullivan reports:

Should the U.S. delay the ICD-10 compliance deadline just one year, until 2014, then the WHO will have a beta of ICD-11 ready. And if Sisko’s gut is correct, and the new ICD-10 deadline flows into 2015, well, then a final version of ICD-11 will be fast-approaching.

When it arrives, currently slated for 2015 (but Chute said it could be 2016), the underlying structure of ICD-11 will be profoundly different than any anterior ICD.

“ICD-11 will be significantly more sophisticated, both from a computer science perspective and from a medical content and description perspective,” Chute explains. “Each rubric in ICD-11 will have a fairly rich information space and metadata around it. It will have an English language definition, it will have logical linkages with attributes to SNOMED, it will have applicable genomic information and underpinnings linked to HUGO, human genome standard representations.”

ICD-10, as a point of contrast, provides a title, a string, a number, inclusion terms and an index. No definitions. No linkages because it was created before the Internet, let alone the semantic web. No rich information space.”

 

HHS Secretary Kathleen Sebelius announces intent to delay ICD-10 compliance date

February 16, 2012 | Carl Natale, Editor, ICD10Watch

Health and Human Services (HHS) Secretary Kathleen G. Sebelius confirmed Wednesday that they will change the ICD-10 timeline.

A HHS press release stated they “will initiate the rulemaking process to postpone the date by which certain health care entities have to comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10).”

On Tuesday, Marilyn Tavenner, the acting administrator of the Centers for Medicare and Medicaid Services (CMS), said the agency will examine the ICD-10-CM/PCS timeline. Tavenner made the statement at a conference of the American Medical Association (AMA) National Advocacy Conference. The AMA has declared vigorous opposition to the medical coding system citing the cost, complexity and lack of perceived benefit to patients… Read on

 

CMS Public Affairs Press Release:

http://www.dhhs.gov/news/press/2012pres/02/20120216a.html

News Release
Contact: CMS Public Affairs
(202) 690-6145

FOR IMMEDIATE RELEASE
February 16, 2012

HHS announces intent to delay ICD-10 compliance date

As part of President Obama’s commitment to reducing regulatory burden, Health and Human Services Secretary Kathleen G. Sebelius today announced that HHS will initiate a process to postpone the date by which certain health care entities have to comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes (ICD-10).

The final rule adopting ICD-10 as a standard was published in January 2009 and set a compliance date of October 1, 2013 – a delay of two years from the compliance date initially specified in the 2008 proposed rule. HHS will announce a new compliance date moving forward.

“ICD-10 codes are important to many positive improvements in our health care system,” said HHS Secretary Kathleen Sebelius. “We have heard from many in the provider community who have concerns about the administrative burdens they face in the years ahead. We are committing to work with the provider community to reexamine the pace at which HHS and the nation implement these important improvements to our health care system.”

ICD-10 codes provide more robust and specific data that will help improve patient care and enable the exchange of our health care data with that of the rest of the world that has long been using ICD-10. Entities covered under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) will be required to use the ICD-10 diagnostic and procedure codes.

Report:

http://www.healthcarefinancenews.com/news/could-us-skip-icd-10-and-leapfrog-directly-icd-11

Could the U.S skip ICD-10 and leapfrog directly to ICD-11?

February 16, 2012 | Tom Sullivan, Government Health IT

Practice Central on ICD-10-CM transition; APA Monitor and WHO Reed on ICD-11

Two articles on forthcoming classification systems: the first on ICD-10-CM from Practice Central; the second on ICD-11 from the February 2012 edition of the American Psychological Association’s “Monitor on Psychology”

Post #140 Shortlink: http://wp.me/pKrrB-1Tt

Update: Medicare could delay burdensome rules on doctors | Julian Pecquet, for The Hill, February 14, 2012

“The acting head of the Medicare agency said Tuesday that she is considering giving the nation’s doctors more time to switch to a new insurance coding system that critics say would cost millions of dollars for little gain to patients.

“Marilyn Tavenner, the acting administrator of the Centers for Medicare and Medicaid Services, told a conference of the American Medical Association (AMA) that her agency could delay adoption of the so-called ICD-10 system. Current law calls for physicians to adopt the new codes next year…

“…Speaking to reporters after her prepared remarks, Tavenner said her office would formally announce its intention to craft new regulations “within the next few days.”

ICD-10 Deadline Review Update | Andrea Kraynak, for HealthLeaders Media, February 15, 2012

“Big news regarding the ICD-10-CM/PCS implementation timeline came Tuesday morning during the American Medical Association (AMA) National Advocacy Conference in Washington, DC.”

“Per CMS acting administrator Marilyn Tavenner, CMS plans to revisit the current implementation deadline of October 1, 2013. Tavenner said CMS wants to reexamine the pace of implementing ICD-10 and reduce physicians’ administrative burden, according to an AMA tweet…”

Practice Central: Resources for Practicing Psychologists

Practice Central, a service of the APA Practice Organization (APAPO), supports practicing psychologists in all settings and at all stages of their career. APAPO is a companion organization to the American Psychological Association. Our mission is to advance and protect your ability to practice psychology.

http://www.apapracticecentral.org/update/2012/02-09/transition.aspx

Practice Update | February 2012

Transition to the ICD-10-CM: What does it mean for psychologists?

Psychologists should be aware of and prepare for the mandatory shift to ICD-10-CM diagnosis codes in October 2013

By Practice Research and Policy staff

February 9, 2012—Beginning October 1, 2013 all entities, including health care providers, covered by the Health Insurance Portability and Accountability Act (HIPAA) must convert to using the ICD-10-CM diagnosis code sets. The mandate represents a fundamental shift for many psychologists and other mental health professionals who are far more attuned to the American Psychiatric Association’s Diagnostic and Statistical Manual of Mental Disorders (DSM).

Most psychologists were trained using some version of DSM. For other health care providers, the World Health Organization’s International Classification of Diseases and Related Health Problems (ICD) – which contains a chapter on mental disorders – is the classification standard.

Over the years, efforts to harmonize these two classifications have resulted in systems with similar (often identical) codes and diagnostic names. In fact, even if psychologists record DSM diagnostic codes for billing purposes, payers recognize the codes as ICD-9-CM – the official version of ICD currently used in the United States. Since 2003, the ICD-9-CM diagnostic codes have been mandated for third-party billing and reporting by HIPAA for all…

Read full article here

 

Dr Geoffrey M. Reed, PhD, Senior Project Officer, WHO Department of Mental Health and Substance Abuse, is seconded to WHO through IUPsyS (International Union for Psychological Science). Dr Reed co-ordinates the International Advisory Group for the Revision of ICD-10 Mental and Behavioural Disorders.

Meetings of the International Advisory Group are chaired by Steven Hyman, MD, Harvard University, Cambridge, MA, a former Director of the National Institute of Mental Health (NIMH) and DSM-5 Task Force Member.

The Department of Mental Health and Substance Abuse will also be managing the technical part of the revision of Diseases of the Nervous System (currently Chapter VI), as it is doing for Chapter V.

February 2012 edition of the American Psychological Association’s “Monitor on Psychology”:

http://www.apa.org/monitor/2012/02/disorder-classification.aspx

Feature

Improving disorder classification, worldwide

With the help of psychologists, the next version of the International Classification of Diseases will have a more behavioral perspective.

By Rebecca A. Clay

February 2012, Vol 43, No. 2

Print version: page 40

What’s the world’s most widely used classification system for mental disorders? If you guessed the Diagnostic and Statistical Manual of Mental Disorders (DSM), you would be wrong.

According to a study of nearly 5,000 psychiatrists in 44 countries sponsored by the World Health Organization (WHO) and the World Psychiatric Association, more than 70 percent of the world’s psychiatrists use WHO’s International Classification of Diseases (ICD) most in day-to-day practice while just 23 percent turn to the DSM. The same pattern is found among psychologists globally, according to preliminary results from a similar survey of international psychologists conducted by WHO and the International Union of Psychological Science.

“The ICD is the global standard for health information,” says psychologist Geoffrey M. Reed, PhD, senior project officer in WHO’s Department of Mental Health and Substance Abuse. “It’s developed as a tool for the public good; it’s not the property of a particular profession or particular professional organization.”

Now WHO is revising the ICD, with the ICD-11 due to be approved in 2015. With unprecedented input from psychologists, the revised version’s section on mental and behavioral disorders is expected to be more psychologist-friendly than ever—something that’s especially welcome given concerns being raised about the DSM’s own ongoing revision process. (See “Protesting proposed changes to the DSM” .) And coming changes in the United States will mean that psychologists will soon need to get as familiar with the ICD as their colleagues around the world…

Read full article here

For more information about the ICD revision, visit the World Health Organization.

Rebecca A. Clay is a writer in Washington, D.C

ICD-11 Beta drafting platform for release in May 2012

ICD-11 Beta drafting platform for release in May 2012

Post #139 Shortlink: http://wp.me/pKrrB-1SE

ICD-11 Beta drafting platform

ICD Revision on Facebook has announced that a ‎4th Face to Face meeting of the ICD Revision Topic Advisory Group for Internal Medicine (TAG IM) was held recently, in Tokyo.

No agenda, meeting materials or documents have been posted on the ICD-11 Revision Google site but a PowerPoint presentation prepared by WHO’s, Dr Bedirhan Üstün, is viewable here on the “Slideshare” platform.

Dr Bedirhan Üstün is Coordinator, Classifications, Terminology and Standards, Department of Health Statistics and Information, WHO, Geneva.

You won’t need a PowerPoint .pptx format viewer to view this presentation on the Slideshare site, but you will need a .pptx viewer if you want to download and view the file. (A free .pptx viewer can be downloaded for free from the Microsoft site.)

In order to download the file, you will first need to register with Slideshare or use a Facebook membership as Sign in. If you do agree to download through a Facebook membership, please read and digest the T & C before you agree to Slideshare accessing your Facebook profile data.

View the presentation here:

http://www.slideshare.net/ustunb/tokyo-2012-ustun-show

Tokyo 2012 ustun (show) by Bedirhan Ustun on Feb 10, 2012

for which it states:

“WHO is revising the ICD to be completed by 2015. It is going to enter into a Beta phase by 2012 May during which all stakeholders could see and comment on the ICD as well as propose changes, test in practice.”

Slide #7 states:

2011  : Alpha version (ICD 11 alpha draft)

– + 1 YR  : Commentaries and consultations

2012  : Beta version & Field Trials Version

– + 2 YR Field Trials

2014   : Final version for public viewing

– 2015  : WHA Approval

2015+  implementation

Slides #11 and #12, set out the thirteen parameters of the ICD-11 “Content Model”.

 

The “Content Model”

ICD Revision says that the most important difference between ICD-10 and ICD-11 will be the Content Model.

Content in ICD-11 will be populated in accordance with the ICD-11 Content Model Reference Guide. There is the potential for considerably more content to be included for diseases, disorders and syndromes in ICD-11 than appears in ICD-10, across all chapters:

“Population of the Content Model and the subsequent review process will serve as the foundation for the creation of the ICD-11. The Content Model identifies the basic characteristics needed to define any ICD category through use of multiple parameters (e.g. Body Systems, Body Parts, Signs and Symptoms, Diagnostic Findings, Causal Agents, Mechanisms, Temporal Patterns, Severity, Functional Impact, Treatment interventions, Diagnostic Rules).”

This is the most recent available version of the Content Model Reference Guide January 2011

This iCAT Glossary page gives an overview of the 13 Content Model parameters.

See also Post #62: ICD-11 Content Model Reference Guide: version for December 2010

 

New Beta drafting browser

In May 2011, a publicly viewable ICD-11 Alpha Browser platform was launched.

In July 2011, this platform was opened up to professionals and other interested stakeholders who can register via the site for fuller access and for reading and submitting comments. See the ICD-11 Alpha Browser User Guide for information on how the Browser functions and how to register for increased access. (This is the Alpha/Beta “hybrid” referred to in the WHO-FIC Council conference call report, February 16, 2011: Page 6: PDF for Report)

ICD-11 Revision and Topic Advisory Groups are continuing to use a separate platform for drafting purposes.

Stakeholder participation at the Beta stage

In preparation for the Beta drafting stage, another publicly viewable platform is being developed. According to ICD Revision presentations, this platform will invite and support a higher level of professional and public interaction with the drafting process, with various levels of input and editing authority for interested stakeholders who register for participation. According to editing status, registered stakeholders would be permitted to:

Make comments
Make proposals to change ICD categories
Participate in field trials
Assist in translating

See presentation slides in Dx Revision Watch Posts #70 and #71:

ICD Revision Process Alpha Evaluation Meeting 11 – 14 April 2011: The Way Forward?

ICD Revision Process Alpha Evaluation Meeting documents and PowerPoint slide presentations

 

Slides #15 and #16 of Dr Üstün’s presentation show the methods via which interested stakeholders will be able to register for interaction with the platform.

I will update when more information becomes available on the launch of the Beta platform.

CFSAC November 2011 meeting: videos, presentations and coding of CFS in ICD-10-CM

CFSAC November 2011 meeting: videos, presentations and Day One Agenda item:

International Classification of Diseases – Clinical Modification (ICD-CM): Presentation by Donna Pickett, RHIA, MPH, National Center for Health Statistics (NCHS)

Post #118 Shortlink: http://wp.me/pKrrB-1xk

The Chronic Fatigue Syndrome Advisory Committee (CFSAC) provides advice and recommendations to the Secretary of Health and Human Services via the Assistant Secretary for Health of the U.S. Department of Health and Human Services on issues related to chronic fatigue syndrome (CFS).

The two day fall meeting of the Chronic Fatigue Syndrome Advisory Committee (CFSAC) took place on Tuesday, November 8 and Wednesday, November 9, 2011 at a new venue – the Holiday Inn Capitol, Columbia Room, 550 C Street, SW, Washington, DC.

No live video streaming

In May 2009, a precedent was set for the entire proceedings of CFSAC meetings to be streamed as real-time video with videocasts and auto subtitling posted online a few days after the meetings have closed.

Prior to the November meeting, CFSAC Committee Support Team had clarified that the commitment to providing real-time video streaming could not be met (later said to be due to budgetary constraints) and that a phone link would be provided instead – an option not available to those of us outside the US – and that a high quality video of the two day proceedings would be posted within a week. In the event, videos for Day One and Day Two of the meeting were not posted within this timeframe.

 

International Classification of Diseases  – Clinical Modification (ICD-CM):
Presentation by Donna Pickett, RHIA, MPH, National Center for Health Statistics (NCHS)

The Agenda items that have the most relevance for Dx Revision Watch site are the presentation on Day One by Donna Pickett (NCHS) and the Committee’s formulation on Day Two of a revised CFSAC Recommendation to HHS on the coding of CFS in the forthcoming ICD-10-CM.

The video for that section of the meeting wasn’t published on YouTube until November 17, just one day prior to the closing date for submission of comments on the proposals for the coding of CFS in ICD-10-CM put forward by the Coalition4ME/CFS for NCHS consideration and an alternative option presented by NCHS at the September 14, 2011 meeting of the ICD-9-CM Coordination and Maintenance Committee [1].

This meant that many of those compiling comment for submission before the November 18 deadline who had not attended the CFSAC meeting in person were unable to use Ms Pickett’s presentation to inform their submissions as they were not aware that the videos for Day One had been published or would have already submitted their comments.

Ms Pickett’s presentation slides can be viewed here in PDF format: PowerPoint Slides

 

The video of Ms Pickett’s presentation can be viewed below or on YouTube:

Uploaded by WomensHealthgov on 17 Nov 2011
Chronic Fatigue Syndrome Advisory Committee (CFSAC) Meeting, Day 1, November 8, 2011. 9am to 11:15am. Opening Remarks, International Classification of Diseases-Clinical Modification (ICD-CM), and Public

 

During her presentation, Ms Pickett had outlined the two proposals under consideration (Option 1 and Option 2) but the slide for the NCHS’s suggestion (Option 2) omits the suggested Excludes.

Note also that the presentation slides did not set out that NCHS has suggested the inclusion term “Chronic fatigue syndrome NOS” under a suggested subcode, “G93.32 Chronic fatigue syndrome”

I consider Option 2 (NCHS) to be problematic for a number of reasons and I was unable to support the NCHS’s suggestion. I could not support:

the suggested revision of the existing ICD Title term “G93.3 Postviral fatigue syndrome” to “G93.3 Postviral and other chronic fatigue syndromes”;

the inclusion of term “Chronic fatigue syndrome NOS” included under “G93.32 Chronic fatigue syndrome”;

the specification of class 2 exclusions, that is, “Excludes2” rather than “Excludes1”.

 

If consideration were being given to the creation of separate subcodes or child categories to a revised parent G93.3 class, then I would prefer to see three discrete subcodes under G93.3, one for each term, in the order: G93.31 Postviral fatigue syndrome; G93.32 Myalgic encephalomyelitis (Benign); G93.33 Chronic fatigue syndrome under an alternative term to the suggested parent term, “G93.3 Postviral and other chronic fatigue syndromes”.

Given that I consider NCHS Option 2 to be problematic and given that no alternatives appear to be currently under consideration by NCHS, I submitted a comment supporting Option 1 (Coalition4ME/CFS), with two caveats:

a) That any excludes specified are Excludes1 not Excludes2

b) That consideration is given by NCHS to specifying two exclusion terms beneath G93.3

Excludes1 chronic fatigue, unspecified (R53.82)
                 neurasthenia (F48.8) 

 

I have reviewed the September ICD-9-CM Coordination and Maintenance Committee meeting audio [5] and do not consider there had been adequate discussion at the meeting of the implications for the inclusion of a “Chronic fatigue syndrome NOS (Not Otherwise Specified)” coded to a suggested subcode “G93.32 Chronic fatigue syndrome”.

The implications for this suggestion do not appear to have been discussed publicly at the November CFSAC meeting nor were the potential implications for the use of “Excludes2” class excludes raised during public discussion.

 

New CFSAC November 2011 Meeting Recommendation

The Minutes for the November CFSAC meeting and the approved Recommendations formulated at that meeting are not yet published on the CFSAC site. [Update @ March 27, 2012: Minutes are available here ]

At the May 2011 meeting, following discussion of the ICD-10-CM CFS coding issue and concerns for the current proposals of the DSM-5 Somatic Symptom Disorders work group, the following Recommendation had been proposed by Dr Lenny Jason and voted unanimously in favour of by CFSAC committee:

 http://www.hhs.gov/advcomcfs/recommendations/05112011.html 

The CFSAC May 2011 Recommendation:

CFSAC rejects current proposals to code CFS in Chapter 18 of ICD-10-CM under R53.82: Chronic fatigue, unspecified > Chronic fatigue syndrome NOS.

CFSAC continues to recommend that CFS should be classified in ICD-10-CM in Chapter 6 under “diseases of the nervous system” at G93.3, in line with ICD-10 and ICD-10-CA (the Canadian Clinical Modification), and in accordance with the Committee’s recommendations of August 2005.

CFSAC considers CFS to be a multi-system disease and rejects any proposals to classify CFS as a psychiatric condition in US disease classification systems. (Note: no disease classification system under HHS’ control proposes to move or to include CFS in or among psychiatric conditions.)

Following committee discussions at the November meeting, this May 2011 Recommendation was reviewed and expanded on to reflect the developments at the September 14 meeting of the ICD-9-CM Coordination and Maintenance Committee and CFSAC committee’s views on the two Options that have been proposed and are under consideration.

CFSAC committee member and disability attorney, Steven Krafchick, read out a motion for a new Recommendation which was proposed and voted unanimously in favour of:

The CFSAC November 2011 Recommendation:

CFSAC considers CFS to be a multi-system disease and rejects any proposal to classify CFS as a psychiatric condition in the US disease classification systems.

CFSAC rejects the current classification of CFS in Chapter 18 of ICD-10-CM under R53.82 – chronic fatigue,  unspecified > chronic fatigue syndrome Not Otherwise Specified.

CFSAC continues to recommend that CFS should be classified in ICD-10-CM in Chapter 6 under “Diseases of the nervous system” at G93.3, in line with ICD-10 (the World Health Organization) and ICD-10-CA (the Canadian Clinical Modification), and in accordance with the Committee’s recommendations of August 2005 and May 2011.

CFSAC rejects the National Center for Health Statistics Option 2 and recommends that CFS remain in the same code and the same subcode as [benign] myalgic encephalomyelitis because CFS includes both viral and non-viral triggers.

CFSAC recommends that an “Excludes1” be added to G93.3 for chronic fatigue – R53.82 and neurasthenia – F48.0.* CFSAC recommends that these changes be made in ICD-10-CM prior to its roll out in 2013.

*Ed: Note: CFSAC committee has been advised that the discrete code for Neurasthenia in ICD-10-CM Chapter 5 is F48.8 not F48.0, as had been read out at the meeting. I am informed that the new Recommendation is being amended.

 

Watch a video clip for the Recommendation, here:

Uploaded by coalition4mecfs on 17 Nov 2011
CFSAC Committee Recommendation on the ICD-10 -11/9/2011

 

Watch discussion of Recommendation and vote here: [1 hr 12 mins from start]

CFSAC November 9, 2011, 1:30 pm – 4:30 pm

Uploaded by WomensHealthgov on 18 Nov 2011
Chronic Fatigue Syndrome Advisory Committee (CFSAC) Meeting, Day 2, November 9, 2011. 1:30pm to 4:30pm. Public Comment and Committee Discussion to Finalize Recommendations

 

Request for clarification 

During her presentation to CFSAC, in response to a query from the floor, Ms Pickett had clarified that the comments being received by NCHS were not being reviewed until after the closing date for submissions (November 18) and that a decision about the proposals would be made in December. At the time of publication, no decision has been made public and it is not known whether any decision has been arrived at.

On December 18, I emailed Ms Pickett and asked if she could advise me by what date a decision is expected to have been made following review and consideration of the comments on proposals for the coding and chapter placement of Chronic fatigue syndrome for ICD-10-CM that were received by her office between September 14 and November 18.

On the CDC website it states that:

The ICD-9-CM Coordination and Maintenance Committee’s role is advisory. All final decisions are made by the Director of NCHS and the Administrator of CMS. Final decisions are made at the end of the year and become effective October 1 of the following year.”

I also asked Ms Pickett if she would clarify if this meant that any decision arrived at by the Coordination and Maintenance Committee is advisory only and whether a final decision would be made by the Director of NCHS and Administrator of CMS; if this is the case, by what date would their decision expect to be made and by what means would a decision be made public.

I will update when I have a response from Ms Pickett and/or when any decision has been reached and announced.

 

Key documents from the November CFSAC meeting

CFSAC Meetings Page

November 8-9, 2011 CFSAC Meeting Agenda

Presentations

Videos of proceedings

Day One: Tuesday, November 8, 2011

CFSAC November 8, 2011; 9:00 – 11:15 am |  Presentation by Donna Pickett, NCHS  Presentation slides 
CFSAC November 8, 2011; 11:30 am – 1:00 pm |
CFSAC November 8, 2011, 2 pm – 4 pm |
CFSAC November 8, 2011, 4 pm – 5 pm |

Day Two: Wednesday, November 9, 2011

CFSAC November 9, 2011, 9 am – 10:30 am
CFSAC November 9, 2011, 10:45 am – 1:15 pm |
CFSAC November 9, 2011, 1:30 pm – 4:30 pm |  Discussion of wording of Recommendation at 1hr 12mins

Presentations

Tuesday, November 8, 2011

Donna Pickett, CDC  International Classification of Diseases – Clinical Modification (PDF– 91.8 KB)

Future Interdisciplinary Research for ME/CFS that Require a Variety of Scientific Disciplines (PDF –  1,008 KB)

Wednesday, November 9, 2011

International Classification of Functioning, Disability and Health: Application and Relevance to Chronic Fatigue Syndrome (PDF – 1 MB)
CDC Report for CFSAC – CFS Activities Since May 2011 (PDF – 208 KB)
Minimum Data Elements for Research Reports on CFS (PDF – 1,016 KB)
NIH Report for CFSAC (PDF – 241 KB)

Public Testimony 

See this CFSAC page for list of Public Testimony and PDFs of testimonies for

Day One: Tuesday, November 8, 2011
Day Two: Wednesday, November 9, 2011

See this CFSAC page for PDFs of Written Testimony Received Prior to the Meeting Date.

Marly Silverman’s Public Testimony on behalf of the Coalition4ME/CFS on the issue of the proposed coding of CFS in the forthcoming US specific ICD-10-CM:

http://www.hhs.gov/advcomcfs/meetings/presentations/publictestimony_201111_sillverman.pdf

 

The two proposals

The Coalition4ME/CFS had submitted a proposal to NCHS, prior to the September meeting, requesting that Chronic fatigue syndrome be deleted as an inclusion term under code R53.82 Other malaise and fatigue (Chapter 18 Symptoms, signs and abnormal clinical and laboratory findings, not elsewhere classified) and that the term be added as an inclusion term under code G93.3 Postviral fatigue syndrome (Chapter 6 Disorders of the nervous system).

The Coalition 4 ME/CFS had also requested that their proposal be considered for October 1, 2012 so that the change occurs prior to the October 1, 2013 implementation date of ICD-10-CM even though the condition is not a new disease.

Ed: Note: Option 1 (Proposal by the Coalition4ME/CFS) does not display the term Benign myalgic encephalomyelitis under G93.3 Postviral fatigue syndrome. This is because no change to the placement of this term was being requested by the Coalition4ME/CFS, that is, there was no proposal to Add, Delete or Revise the term Benign myalgic encephalomyelitis other than a request that consideration be given to placing the ICD-10 descriptor “Benign” at the end of the term, as “Myalgic encephalomyelitis (Benign)”.

[Image source: Page 11, Diagnosis Agenda: ICD-9-CM Coordination and Maintenance Committee Meeting September 14, 2011  http://www.cdc.gov/nchs/data/icd9/TopicpacketforSept2011a.pdf ]

 

Ed: Note: At the September 14, 2011 ICD-9-CM Coordination and Maintenance Committee meeting, there had been some brief discussion of whether class 1 excludes (Excludes1) were more appropriate than class 2 excludes (Excludes2). Clarification of the difference between the terms follows:

Source: ICD-10-CM TABULAR LIST of DISEASES and INJURIES, Instructional Notations 

Excludes Notes

The ICD-10-CM has two types of excludes notes. Each note has a different definition for use but they are both similar in that they indicate that codes excluded from each other are independent of each other.

Excludes1

A type 1 Excludes note is a pure excludes. It means “NOT CODED HERE!” An Excludes1 note indicates that the code excluded should never be used at the same time as the code above the Excludes1 note. An Excludes1 is for used for when two conditions cannot occur together, such as a congenital form versus an acquired form of the same condition.

Excludes2

A type 2 excludes note represents “Not included here”. An excludes2 note indicates that the condition excluded is not part of the condition it is excluded from but a patient may have both conditions at the same time. When an Excludes2 note appears under a code it is acceptable to use both the code and the excluded code together.

 

References

[1] Meeting materials September 14, 2011 meeting of the ICD-9-CM Coordination and Maintenance Committee 

[2] Coding CFS in ICD-10-CM: CFSAC and the Coalition4ME/CFS initiative

[3] Extracts from Diagnosis Agenda: ICD-9-CM Coordination and Maintenance Committee Meeting September 14, 2011 (Coding of CFS in ICD-10-CM)     [Post sets out proposals: Option 1 from Coalition4ME/CFS and Option 2 from NCHS, which are also set about below.]

[4] Extracts: ICD-9-CM Coordination and Maintenance Committee Meeting Summary of Diagnosis Presentations September 14, 2011 (CFS Coding)

[5] Audio of September 14 NCHS ICD-9-CM meeting http://www.cms.gov/ICD9ProviderDiagnosticCodes/Downloads/091411_Meeting_Audio.zip

[Note this audio downloads as a large Zipped file.  The section for discussions on CFS coding starts at 2 hours 27 minutes in from start and ends at 3 hours 02 minutes.]

Psychiatric Manual Revision Pushes Ahead Amid Continued Concerns (APA issues update on status of DSM-5)

Psychiatric Manual Revision Pushes Ahead Amid Continued Concerns (APA issues update on status of DSM-5)

Post #115 Shortlink: http://wp.me/pKrrB-1qV

Wall Street Journal Health Blog

WSJ’s blog on health and the business of health

Psychiatric Manual Revision Pushes Ahead Amid Continued Concerns

Shirley S. Wang | November 23, 2011

The American Psychiatric Association’s years-long efforts to revamp its big book of diagnoses has been fraught with controversy.

Critics have said that the committee charged with the fifth full revision of the Diagnostic and Statistical Manual for Mental Disorders, known as the DSM, is being too secretive and trying to make too many changes, among other concerns.

Read full article

On November, 23, the American Psychiatric Association posted a statement “Update on the Status of DSM-5” (dated November 22, 2011) on its main website.

Open PDF here: APA Update on the Status of DSM-5 11.22.11

or open on the APA’s website here

Text version follows:

APA Provides Update on Status of DSM-5

The development of DSM-5, more than a decade in process, has been the object of immense public and professional interest. APA hopes that the following information about the process and substance of the emerging diagnostic manual—which will be published in 2013 and at this point is by no means a finished product—will be useful and clarifying. Certainly, everyone with an interest in DSM-5 should visit its open access Web site, www.dsm5.org/Pages/Default.aspx, which has comprehensive information about the developing manual.

The process of developing DSM-5 began in 1999, when APA and the National Institute on Mental Health (NIMH) convened a conference to begin creating a research agenda for the new diagnostic manual. In 2002, APA published A Research Agenda for DSM-5. In the ensuing years, APA worked with multiple agencies—NIMH, the World Health Organization (WHO), the World Psychiatric Association, the National Institute on Drug Abuse, and the National Institute on Alcohol Abuse and Alcoholism—involving hundreds of participants and resulting in hundreds of publications and monographs, most of which are available on the DSM-5 Web site, regarding current state of knowledge, gaps in research, and recommendations for further research.

The DSM-5 Task Force was formed in 2007, with 13 work groups composed of world-renowned leaders in psychiatric research, diagnosis, and treatment. Since then, the 160 members of the task force and work groups have reviewed more than a decade of research on specific topics and diagnoses under consideration for the new manual. APA granted work group members permission to publish their literature reviews, and nearly all have been published in peer-reviewed journals (again, many of them available for public review on the DSM-5 Web site). In 2009 guidelines were developed to ensure the standardization of presentations by all work group members as they prepared draft diagnostic criteria and rationales for task force review.

These guidelines were subsequently adopted to facilitate reviews by the Scientific Review Committee.

Importantly, members of the work groups are not APA employees, are not under contract with APA, and are not paid by APA. They are free to leave the work group if at any time they are not satisfied that the process is unbiased or if they believe the results are lacking in scientific integrity.

Work group members come from widely diverse backgrounds and represent academic and mental health institutions throughout the world. Ninety-seven members are psychiatrists, 47 are psychologists, two are pediatric neurologists, three are statistician/epidemiologists, and there is one representative each from pediatrics, social work, pediatric nursing, speech and hearing specialties, and consumer groups. There are also more than 300 outside advisors selected for their particular expertise. Together, all of these professionals have every incentive to ensure the work, and the ultimate product, is based on science and empirical evidence.

Moreover, APA has welcomed the public’s input by making all of the drafts of the evolving document available on the DSM-5 Web site. The drafts that APA has put out for review by the public are posted to elicit comments from others in the field and from patients and family members who may be impacted by changes. APA has received through the Web site alone more than 10,000 comments—each of which has been considered and evaluated by the work groups.

The task force is working on including “dimensional and cross-cutting assessments” in order to diagnose psychiatric disorders in a more detailed and nuanced way and to recognize the frequent comorbidities that exist with many mental illnesses. The measurement instruments used in these assessments are modeled on proven instruments, such as the NIH-developed Patient Reported Outcome Measurement Information System (PROMIS), the PHQ-9 for Major Depression, PHQ-8 for somatic symptoms, the Swanson SNAP scale for attention, the Stringaris scale from NIMH for irritability, and the Altman scale for bipolar disorder. All of these scales are being subjected in field trials to extensive tests of reliability and clinical utility.

The definition of mental disorder used in DSM-IV is undergoing a thorough review by the DSM-5 Task Force. Throughout the review process, APA has assimilated input from around the world and across disciplines and is reformulating its recommendations for the definition of a mental disorder. The task force continues to work toward a definition of mental disorder that is evidence-based and acceptable to the mental health community at large, and APA welcomes comments on the revised definition when it is posted in the third round of revisions expected to come out in the spring.

Throughout this process, APA has been committed to transparency. DSM-5 Task Force and work group members have presented and participated in open discussions at hundreds of psychiatric and other major medical meetings around the world and have received permission whenever requested to publish on the proposed changes in DSM-5 without regard to their point of view. (A list of those meetings and publications is available for review on the DSM-5 Web site.)

APA has asked those involved in the DSM-5 process to sign a member acceptance form that has been the subject of some misunderstanding. The confidentiality portion of the member acceptance form is not intended to promote secrecy, but rather to facilitate the verbal process of deliberation. Most, if not all, scientific institutions—including the National Institutes of Health, the Institute of Medicine, WHO, and all scientific journal preparations and reviews—share results of research and explanations for their conclusions, but do not fully open the deliberative process itself for comment. This is crucial in order to ensure the free-exchange of ideas during deliberation.

The Scientific Review Committee was appointed by the Board of Trustees of APA and charged with the ultimate approval of the final DSM-5 recommendations. As part of that charge, the committee will evaluate the strength of the evidence in support of proposed revisions. This separate peer-review process will provide important guidance to the Board. The committee’s contributions will be reflected in the final criteria of DSM-5. Another committee, the Clinical and Public Health Committee, has recently been appointed by the Board to consider clinical utility and public health issues that are not being reviewed by the Scientific Review Committee.

In addition, APA has worked with WHO on an ongoing basis to develop harmonization between disorders included in both DSM-5 and ICD-11. Public comment has twice been solicited on proposed diagnostic criteria, and a third public comment period is planned for 2012.

APA believes the extensive process of development for DSM-5 will result in a scientifically and clinically useful new edition of the diagnostic manual, and the Task Force is indebted to the hundreds of experts who are contributing to its content.

November 22, 2011

Related information:

1] DSM-5 Development website

2] American Counseling Association releases letter: Calls for external review of DSM-5

3] Coalition for DSM-5 Reform Tab page on Dx Revision Watch site

4] Coalition for DSM-5 Reform website

5] Open Letter and iPetition