Objectors to insertion of DSM-5’s Somatic symptom disorder into ICD-10-CM

Post #283 Shortlink: http://wp.me/pKrrB-3y8

Michael Munoz, Executive Director, Rocky Mountain CFS/ME & FM Association has organized a joint letter of objection signed by 13 U.S. patient organizations and advocates for submission to NCHS. It can be read here:

http://www.rmcfa.org/index.html > http://www.rm-cfs-fms.citymaker.com/f/NCHS.pdf

or download PDF here: Joint response to NCHS 11.15.13

This joint submission had been signed by the following organizations and advocates:

Michael Munoz, Executive Director, Rocky Mountain CFS/ME & FM Association
Lori Chapo-Kroger, RN, President & CEO, PANDORA Org
Charmian Proskauer, President, Massachusetts CFIDS/ME & FM Association
Tamara Staples, President & Co-Founder, Fibromyalgia – ME/CFS Support Center, Inc.
Donna Pearson, Vice President, Massachusetts CFIDS/ME & FM Association
Jean Harrison, President and Founder, MAME – Mothers Against Myalgic Encephalomyelitis
Denise Lopez-Majano, Founder, Speak Up About ME
Rik Carlson, President, Immunedysfunction.org
Jennifer M. Spotila, JD., Occupy CFS blog, Patient Advocate
Billie Moore, Patient Advocate
Charlotte von Salis, JD, Patient Advocate
Mary Schweitzer, Ph.D., Patient Advocate
Mary Dimmock, Patient Advocate

I’d like to thank all those who have submitted objections to NCHS in opposition to the September 2013 C & M Committee meeting proposal to insert Somatic symptom disorder as an inclusion term in ICD-10-CM.

My submission can be read here PDF: Submission NCHS

Some additional organizations and individuals have advised me of their own submissions. If you have submitted a response on behalf of your organization or as a patient, advocate or professional and you would like your name or your organization’s name added to the list of responders below please shoot me an email or contact me via the Contact form with a link to your submission (if it has been placed in the public domain) and a couple of lines of credentials or stakeholder interest, if desired.

Bridget Mildon, Patient advocate and Founder of FND Hope, Inc. FND Hope is the only state registered non profit patient advocacy organization specifically for those assigned a diagnosed of Functional Neurological Disorder. Bridget was misdiagnosed with FND and continues to advocate for those with a FND diagnosis to receive appropriate patient care fndhope.org Submission
Mark Thompson, patient. Submission
Diane O’Leary, Ph.D. is a philosopher focused on the rights of medical patients denied medical care because of mistaken somatoform diagnoses. She is author of the book, Patient, Executive Director of the Sneddon’s Foundation, and author of numerous web and print entries on Sneddon’s Syndrome, a highly threatening cerebrovascular disease generally mistaken for somatoform disorders. Dr. O’Leary is author of “Peculiar Silence: The Problem of Error in Diagnosis of SSD” (a reply piece at BMJ). Dr O’Leary has coauthored several blogs, published and forthcoming, with Prof. Allen Frances at Huffington Post, Psychology Today and Psychiatric Times. New work is forthcoming for the National Organization for Rare Disorders and Ben’s Friends. An audio interview with Dr. O’Leary is available here. PDF Submission also Submission [On LinkedIn]
Suzy Chapman, DipAD, UK carer/advocate for young adult with long-term illness. Owner of website Dx Revision Watch, Monitoring the revision of DSM-5 and ICD-11. Co-author of journal papers and commentaries on the Somatic symptom disorder construct (with Professor Allen Frances). PDF Submission
Richard A. Lawhern, Ph.D. is an 18-year patient advocate. He writes content and moderates for “Living With TN,” a social networking site that supports nearly 5,000 chronic face pain patients in 117 countries – many of whom have been substantively harmed by mis-application of psychosomatic diagnoses. Submission
Angela Kennedy, M.A. (also retired R.G.N.), social science lecturer and researcher. Author of the book Authors of our own misfortune?: The problems with psychogenic explanations for physical illnesses (2012) Village Digital Press. Carer and parent of disabled woman who became ill at 12 years of age.
Gail Kansky, President, National CFIDS Foundation, Inc. Needham, MA http://www.ncf-net.org Submission
Jack Carney, Ph.D., DSW, Brooklyn, NY, Committee to Boycott the DSM-5, contributor to Mad in America. A social worker, Dr Carney writes on the contradictions and hypocrisies of the public mental health system and promotes and applauds acts of resistance to it.
Jennifer Brauer, BA, Women’s Studies, University of Massachusetts. Former certified paramedic, Emergency Medical Technician BLS, Bureau of The Emergency Medical Services, NY City Fire Dept. (1996-2005).
Samuel Wales, author, The Kafka Pandemic

Submission: Objection to proposal to insert DSM-5’s Somatic symptom disorder into ICD-10-CM

Post #281 Shortlink: http://wp.me/pKrrB-3×1

Information in this post relates to proposals submitted via the September ICD-9-CM Coordination and Maintenance Committee meeting for inclusion of additional codes and changes to the forthcoming US specific ICD-10-CM/PCS.

There are just five days is just one day left in which to submit objections to NCHS to the proposal to insert DSM-5’s Somatic symptom disorder into ICD-10-CM.

Submit objections via email by November 15 to Donna Pickett, CDC: nchsicd9CM@cdc.gov

Further information here: Keep SSD out of ICD-10-CM – November 15 deadline for objections

Please let me know if you or your organization or professional body has submitted comment or objections, with a link if your submission is being placed in the public domain.

We need to keep SSD out of ICD-10-CM

Please consider submitting an objection before the November 15 deadline.

If you submitted comment during any of the three DSM-5 public review periods or you are an advocate or clinician signatory to the Institute of Medicine (IOM) definition issue letters campaign please also consider submitting an objection to NCHS.

I have submitted the following:

PDF: Submission NCHS

Text:

To: Ms Donna Pickett, CDC

Re: Comment on proposals, September 18-19, 2013 meeting of the ICD-9-CM Coordination and Maintenance Committee

Diagnostic Agenda, Page 45: Additional Tabular List Inclusion Terms for ICD-10-CM

Add Somatic symptom disorder to ICD-10-CM Tabular List under F45 Somatoform Disorders as inclusion term to F45.1 Undifferentiated somatoform disorder.

Add Somatic symptom disorder to ICD-10-CM Alphabetical Index.

Requestor for proposal: Unspecified

——————————————————–

I am writing to object to the proposed insertion of Somatic symptom disorder into the ICD-10-CM Tabular List and Alphabetical Index.

Somatic symptom disorder is a new construct created by the American Psychiatric Association (APA) for DSM-5.

For DSM-5, the Somatoform Disorders have been dismantled. Four DSM-IV categories: somatization disorder [300.81], some presentations of hypochondriasis [300.7], pain disorder, and undifferentiated somatoform disorder [300.82] are eliminated and replaced with a single new construct, Somatic Symptom Disorder (SSD), cross-walked in DSM-5 to ICD 300.82 (F45.1).

The Somatic Symptom Disorder construct de-emphasizes “medically unexplained” as the central defining feature of this disorder group. The diagnosis does not require that the somatic symptoms are medically unexplained, instead, the focus shifts away from somatic symptoms to emotional, cognitive and behavioral disturbances and “maladaptive” responses: high levels of health anxiety; disproportionate and persistent concerns about the medical seriousness of the symptom(s); or an excessive amount of time and energy devoted to symptoms and health concerns.

Symptoms may or may not be associated with another medical condition: SSD allows for the application of a mental health diagnosis in patients with “established general medical conditions or disorders” like diabetes, heart disease and cancer or presenting with “somatic symptoms of unclear etiology” if the clinician considers the patient otherwise meets the new criteria.

To meet the requirements for DSM-IV Somatization Disorder, a rigorous criteria set needed to be fulfilled: a history of many medically unexplained symptoms before the age of thirty, resulting in treatment sought or psychosocial impairment. And a high diagnostic threshold: a total of eight or more medically unexplained symptoms from four, specified symptom groups, with at least four pain, two gastrointestinal, one psychosexual and one pseudoneurological symptom.

In DSM-5, the requirement for eight symptoms has been dropped to just one or more persistent, non specific, distressing somatic symptoms and the clinician’s perception of “excessive” or “maladaptive” response to the symptom or symptoms.

• These changes for DSM-5 represent a radical restructuring of the DSM-IV Somatoform Disorder categories and a new construct for which much remains to be determined.

On Day Two of the September ICD-9-CM Coordination and Maintenance Committee meeting, Dr Darrel Regier presented and discussed rationales, coding proposals and timings for six new DSM-5 disorders that the APA has proposed for insertion into ICD-10-CM. But the proposal to add the new DSM-5 Somatic symptom disorder and Illness anxiety disorder category terms to ICD-10-CM did not form part of Dr Regier’s presentation on behalf of the APA.

As it is unspecified within the Diagnosis Agenda and during the meeting presentations, it is unclear whether these two proposals are being requested by the APA, by NCHS/CMS, or by other parties or individuals.

• My first concern is that no description of Somatic symptom disorder, no rationale for why this ICD-10-CM change is needed (including clinical relevancy) and no supporting clinical and literature references for the validity of Somatic symptom disorder as a new disorder term were published in the Diagnosis Agenda.

At the public meeting, no presentation had been made on behalf of APA, or by representatives of NCHS or CMS, or by anyone else for the specific proposal to add Somatic symptom disorder as an inclusion term under the ICD-10-CM Somatoform disorders and there was no discussion of this proposal during the course of the meeting [1][2].

There is an expectation that the committees overseeing the development and revision of the draft for the ICD-10-CM will give due consideration to the applicability, clinical utility and reliability of any proposal for the inclusion of a new disorder construct before granting approval for addition to the Tabular List and Index, and that the comments and objections received during the public response period will also be considered.

The lack of rationales and references for supportive evidence provided by the requestors hinders public participation in the response process.

• The absence from both the Diagnosis Agenda document and the meeting presentations of rationales, clinical relevancy and supporting clinical and literature references to enable public scrutiny, consideration and informed responses to this proposal should disqualify SSD from consideration for implementation during a partial code freeze or for consideration for implementation in October 2015.

The burden of proof before introducing any new diagnosis into a classification system is that it has a favourable risk to benefit ratio. This new construct created by the APA for its DSM-5 merits the same level of scrutiny and risk to benefit evaluation as would be expected to be applied to any proposed new disorder/disease under consideration for inclusion in any chapter of ICD, whether this is for the updating of the ICD-10-CM draft, the international ICD-10, the several clinical modifications of ICD-10 or the drafting of ICD-11.

A number of papers have remarked on the paucity of rigorous evidence for the validity, reliability, acceptability, safety and utility of the SSD construct applied to adults and children in diverse clinical settings and across a spectrum of health and allied professionals.

There is no significant body of published research on the epidemiology, clinical characteristics or treatment of the Somatic symptom disorder construct [3][4][5].

In a paper published in the Journal of Psychosomatic Research, September 2013, the SSD work group concedes the lack of clinical evidence for its new construct and acknowledges the “small amount of validity data concerning SSD”; “that much remains to be determined” about the utility and reliability of the specific SSD criteria and its thresholds when applied in busy, general clinical practice, and there are “vital questions that must be answered” as they go forward [6].

• As an under researched, poorly validated disorder construct, Somatic symptom disorder does not meet NCHS/CMS criteria for “new diseases/new technology procedures, and any minor revisions to correct reported errors in these classifications” and should be rejected for consideration for implementation during a partial code freeze but also rejected for consideration for implementation in October 2015.

Concerns for the looseness of the SSD definition and the ease with which these new criteria can be met have been discussed in a number of published papers and commentaries [7][8][9].

The over-inclusiveness of the SSD diagnosis is borne out by the results of the DSM-5 field trial study reported by the chair of the Somatic symptom disorder work group at the 2012 annual meeting of the American Psychiatric Association.

15% of the ‘diagnosed illness’ study group, comprising patients with cancer or coronary disease, were caught by SSD and would meet the criteria for application of an additional mental disorder diagnosis.

26% of the ‘functional somatic’ study group, patients with irritable bowel syndrome or chronic widespread pain, met the SSD criteria.

SSD has a high false positive rate – capturing 7% of the ‘healthy’ field trial control group.

It is also disturbing that the SSD work group (which included no primary care physicians) appears not to have undertaken any field trials into the safety of application of the SSD criteria in children and adolescents.

NCHS/CMS provides no references for data for the application of SSD in children within the Diagnosis Agenda, although the DSM-5 text clearly indicates APA’s intention that SSD is a diagnosis that may also be applied to children with persistent, distressing somatic symptoms.

Potential implications for the application of a diagnosis of SSD:

I am not persuaded that the new SSD construct and criteria can be safely applied outside the optimal conditions of field trials, in settings where practitioners may not necessarily have adequate time for, or instruction in the administration of diagnostic assessment tools, and where decisions to code or not to code may hang on the arbitrary and subjective perceptions of a wide range of end-users who may lack clinical training in the application of mental disorder criteria.

Misapplication of highly subjective and loose, easily met criteria, especially in busy primary care practice, may result in inappropriate diagnoses of mental disorder and inappropriate medical decision making [10], with considerable implications for patients (see Appendix).

A mental disorder diagnosis of SSD can be applied as a “bolt-on” to any chronic medical diagnosis, eg patients with diabetes, angina, cancer, MS, cardiovascular disease, ME and CFS, IBS, chronic widespread pain (aka fibromyalgia) or to patients with a chronic pain condition or with persistent symptoms of unclear etiology.

Patients with chronic, multiple bodily symptoms due to rare diseases, difficult to diagnoses diseases, or multi-system diseases like Behçet’s disease, which can take several years to arrive at a diagnosis, may be especially vulnerable to missed diagnosis or to misdiagnosis with a mental disorder, which may impede access to further testing, investigations, interventions and effective treatments (and result in increased claims against practitioners for medical negligence).

Patients with chronic fatigue syndrome (CFS), “almost a poster child for medically unexplained symptoms as a diagnosis,” according to SSD work group chair, Joel E Dimsdale, or chronic Lyme disease, Gulf War illness, chemical injury and chemical sensitivity; women with potential symptoms of gynecological disease, like ovarian cancer, already often late-diagnosed, endometriosis or interstitial cystitis, or patients with vague neurological symptoms may be particularly vulnerable to misapplication or misdiagnosis with a mental health disorder under the SSD criteria.

There has been considerable opposition to the introduction of this new, poorly tested construct into the DSM-5 amongst patients, carers, advocates, consumer organizations, mental health practitioners and clinicians and considerable concern for the implications for diverse patient populations that the Somatic Symptom Disorder category will provide a “dustbin diagnosis” for the so-called “functional somatic syndromes,” for those living with chronic pain and for patients with persistent, but as yet undiagnosed, symptoms of disease.

• NCHS/CMS has published no independent field trial data and provided no rationales or clinical and literature references to inform public responses. Given the lack of published evidence for the validity and safety of SSD as a construct in adults and children, there is insufficient basis for the approval of SSD for inclusion within ICD-10-CM and it would be scientifically unsafe, premature and against the public interest to include this new construct within ICD.

The proposal for addition to the ICD-10-CM as an inclusion term during a partial code freeze should be rejected. There should be no implementation in October 2015 as an inclusion term to F45.1 or to any other existing code, or with a unique code created.

Appendix:

Incautious, inept application of criteria resulting in a “bolt-on” psychiatric diagnosis of Somatic symptom disorder could have far-reaching implications for diverse patient populations:

• Application of highly subjective and difficult to measure criteria could potentially result in misdiagnosis with a mental disorder, misapplication of an additional diagnosis of a mental disorder or missed diagnoses through dismissal and failure to investigate new or worsening somatic symptoms.

• Patients with cancer and life threatening diseases may be reluctant to report new symptoms that might be early indicators of recurrence, metastasis or secondary disease for fear of attracting a diagnosis of SSD or of being labelled as “catastrophisers.”

• Application of an additional diagnosis of SSD may have implications for the types of medical investigations, tests and treatments that clinicians are prepared to consider and which insurers are prepared to fund.

• Application of an additional diagnosis of SSD may impact payment of employment, medical and disability insurance and the length of time for which insurers are prepared to pay out. It may negatively influence the perceptions of agencies involved with the assessment and provision of social care, disability adaptations, education and workplace accommodations, and the perceptions of medical staff during hospital admissions and accident and emergency admissions.

• Patients prescribed psychotropic drugs for perceived unreasonable levels of “illness worry” or “excessive preoccupation with symptoms” may be placed at risk of iatrogenic disease or subjected to inappropriate and costly behavioural therapies.

• For multi-system diseases like Multiple Sclerosis, Behçet’s disease or Systemic lupus it can take several years before a diagnosis is arrived at. In the meantime, patients with chronic, multiple somatic symptoms who are still waiting for a diagnosis would be vulnerable.

• The burden of the DSM-5 changes to Somatoform Disorders will fall particularly heavily upon women who are more likely to be casually dismissed when presenting with physical symptoms and more likely to be prescribed inappropriate antidepressants and anti-anxiety medications for them.

• Proposals allow for the application of a diagnosis of SSD to children and where a parent is considered excessively concerned with a child’s symptoms. Families caring for children with any chronic illness may be placed at increased risk of wrongful accusation of “over-involvement” with a child’s symptomatology.

Where a parent is perceived as encouraging maintenance of “sick role behavior” in a child, this may provoke social services investigation or court intervention for removal of a sick child out of the home environment and into foster care or enforced in-patient rehabilitation. This is already happening in families in the U.S. and Europe with a child or young adult with chronic illness, notably with Chronic fatigue syndrome or ME. It may happen more frequently with a diagnosis of a chronic childhood illness + SSD.

Thank you for your consideration.

References:

1. September 18-19, 2013 meeting of the ICD-9-CM Coordination and Maintenance Committee Diagnosis Agenda.

2. September 18-19, 2013 meeting of the ICD-9-CM Coordination and Maintenance Committee Summary of Diagnosis Presentations.

3. DSM-5 Somatic Symptom Disorders Work Group Disorder Descriptions and Justification of Criteria – Somatic Symptoms, pub. May 2011, for second DSM-5 stakeholder review.

4. Robert L. Woolfolk and Lesley A. Allen (2012). Cognitive Behavioral Therapy for Somatoform Disorders, Standard and Innovative Strategies in Cognitive Behavior Therapy, Dr. Irismar Reis De Oliveira (Ed.), ISBN: 978-953-51-0312-7

5. Ghanizadeh A, Firoozabadi A. A review of somatoform disorders in DSM-IV and somatic symptom disorders in proposed DSM-V. Psychiatr Danub. 2012 Dec;24(4):353-8.

6. Dimsdale JE, Creed F, Escobar J, Sharpe M, Wulsin L, Barsky A, Lee S, Irwin MR, Levenson J. Somatic Symptom Disorder: An important change in DSM. J Psychosom Res. 2013 Sep;75(3):223-8. Epub 2013 Jul 25.

7. Frances A. The new somatic symptom disorder in DSM-5 risks mislabeling many people as mentally ill. BMJ. 2013 Mar 18;346:f1580. doi: 10.1136/bmj.f1580.

8. Frances A. DSM-5 Somatic Symptom Disorder. J Nerv Ment Dis. 2013 Jun;201(6):530-1. doi: 10.1097/NMD.0b013e318294827c.

9. Frances A, Chapman S. DSM-5 somatic symptom disorder mislabels medical illness as mental disorder. Aust N Z J Psychiatry. 2013 May;47(5):483-4. doi: 10.1177/0004867413484525.

10. Dimsdale JE. Medically unexplained symptoms: a treacherous foundation for somatoform disorders? Psychiatr Clin North Am 2011;34:511-3.

Interest:

Carer/advocate for young adult with long-term medical condition. Owner of website Dx Revision Watch, Monitoring the revision of DSM-5 and ICD-11. Co-author, journal papers and commentaries on the SSD construct (with Professor Allen Frances).

[End of submission]

DSM-5 Round up: April #1

DSM-5 Round up: April #1

Post #231 Shortlink: http://wp.me/pKrrB-2In

New York Post

A disease called ‘childhood’

Do 1 in 5 NYC preteens really suffer a mental woe? A psychiatry expert argues we’re overdiagnosing —and overmedicating — our kids

Allen Frances MD | March 30, 2013

Last week, The Post reported that more than 145,000 city children struggle with mental illness or other emotional problems. That estimate, courtesy of New York’s Health Department, equals an amazing 1 in 5 kids. Could that possibly be true?

+++
BBC Radio 4

http://www.bbc.co.uk/programmes/b01rl1q8

Medicalising Grief

Will the book that classifies mental illness lead to the medicalisation of grief?

Presented by Matthew Hill. Featuring Drs Jerome Wakefield, Lisa Cosgrove, Allen Frances (Chaired the Task Force for DSM-IV), Joanne Cacciatore and Gary Greenberg.

Available to listen again for the next 7 days online.

Counseling Today ACA podcasts help counselors prepare for DSM-5

Heather Rudow | March 27, 2013

Rebecca Daniel-Burke, ACA’s [American Counseling Association]director of professional projects and staff liaison to ACA’s DSM-5 Task Force, hosts the podcast series, which offers counselors a way to prepare for and understand potential changes. Daniel-Burke spoke with K. Dayle Jones for the first, 38-minute podcast, and Jason King for the second, which is 52 minutes long and available for CE credit…

+++

The New York Times invited readers to respond for a dialogue about psychiatric diagnoses and the forthcoming DSM-5. The dialogue was initiated by a letter from Ronald Pies, which concludes “‘Diagnosis’ means knowing the difference between one condition and another. For many patients, learning the name of their disorder may relieve years of anxious uncertainty. So long as diagnosis is carried out carefully and respectfully, it may be eminently humanizing. Indeed, diagnosis remains the gateway to psychiatry’s pre-eminent goal of relieving the patient’s suffering.”

http://www.nytimes.com/2013/03/20/opinion/invitation-to-a-dialogue-psychiatric-diagnoses.html

Ronald Pies

Controversy surrounding the soon-to-be-released fifth edition of the Diagnostic and Statistical Manual of Mental Disorders, or DSM-5 — often called “psychiatry’s bible” — has cast a harsh light on psychiatric diagnosis. For psychiatry’s more radical critics, psychiatric diagnoses are merely “myths” or “socially constructed labels.” But even many who accept the reality of, say, major depression argue that current psychiatric diagnoses often “stigmatize” or “dehumanize” people struggling with ordinary grief, stress or anxiety…

Published responses:

http://www.nytimes.com/2013/03/24/opinion/sunday/sunday-dialogue-defining-mental-illness.html

Letters
Sunday Dialogue: Defining Mental Illness

Response to Letters from Ronald Pies via Psychiatric Times

http://www.psychiatrictimes.com/blog/pies/content/article/10168/2135248

Diagnosis and its Discontents: The DSM Debate Continues

Ronald W. Pies, MD | 29 March 2013

Dr Pies is Editor-in-Chief Emeritus of Psychiatric Times, and a professor in the psychiatry departments of SUNY Upstate Medical University and Tufts University School of Medicine. He is the author of The Judaic Foundations of Cognitive Behavioral Therapy; a collection of short stories, Ziprin’s Ghost; and, most recently, a poetry chapbook, The Heart Broken Open. His most recent book is The Three-Petalled Rose: How the Synthesis of Judaism, Buddhism, and Stoicism Can Create a Healthy, Fulfilled and Flourishing Life (iUniverse: 2013).

“As to diseases, make a habit of two things—to help, or at least to do no harm.”
–Hippocrates, Epidemics, in Hippocrates, trans. W. H. S. Jones (1923), Vol. I, 165 [italics added]

“An agnostic is someone who doesn’t know, and di– is a Greek prefix meaning “two.” So “diagnostic” means someone who doesn’t know twice as much as an agnostic doesn’t know.”
–Walt Kelly, Pogo

A funny thing happened to me on the way to the New York Times “Sunday Dialogue” —I made myself unclear.¹ This is not supposed to happen to careful writers, or to those of us who flatter ourselves with that honorific. So what went wrong?

In brief, I greatly underestimated the public’s strong identification of psychiatric diagnosis with the categorical approach of the recent DSMs. But whereas my letter to the Times was indeed occasioned by DSM-5’s release in May, my argument in defense of psychiatric diagnosis was not a testimonial in favor of any one type of diagnostic scheme—categorical, dimensional, prototypical² or otherwise…

http://www.meactionuk.org.uk/The-Achilles-Heel.htm

Stephen Ralph | March 30, 2013

In recent years I have been considering the reliability of the whole “CFS/ME” diagnostic process.

From personal experience I have encountered numerous doctors who failed to possess the detailed specialist knowledge they needed to make a diagnosis of Behçet’s disease at both GP and specialist level.

From personal experience I have learned that standard blood tests or even CT/MRI scans or indeed other diagnostic tests such as endoscopy can and do fail to detect a complex clinical disease present in a patient.

I have no doubt that there is a diagnostic black hole between the insufficient knowledge of the doctor and pathologies that are not detectable by the basic tests they choose to request which produce negative results they then choose to rely on.

The diagnoses of “CFS/ME” and now Somatic Symptom Disorder have in my view been deployed by liaison psychiatry to exploit that black hole.

Read more of this post

DSM-5 and ICD-10-CM Round up: February #3

DSM-5 and ICD-10-CM Round up: February #3

Post #227 Shortlink: http://wp.me/pKrrB-2FY

Updates:

American Psychiatric Association News release:

Release No. 13-11: February 28, 2013

APA Annual Meeting in San Francisco, May 18-22; DSM-5 to be Released

ARLINGTON, Va. (Feb. 28, 2013) – The American Psychiatric Association’s 166th Annual Meeting, the world’s largest psychiatric meeting, will run Saturday, May 18 to Wednesday, May 22, 2013 in San Francisco at the Moscone Convention Center. The much anticipated DSM-5, the latest revision of the Diagnostic and Statistical Manual of Mental Disorders, will be released at the meeting…

Clinical Psychiatry News Digital Network

DSM-5 expected to be more ‘user-friendly’

Doug Brunk | March 3, 2013

ABC News Radio

An edited version of the ABC News coverage of concerns for new DSM-5 disorder ‘Somatic Symptom Disorder’ that replaces four DSM-IV Somatoform Disorder categories has been published on ABC News Radio:

Guidelines for Diagnosing Psychiatric Disorder May Overlook Physical Illnesses

CMS pledges commitment to October 1, 2014 ICD-10-CM compliance:

Click link for PDF document   CMS letter

CMS: No Further Delays in ICD-10-CM/PCS Implementation

Chris Dimick | AHIMA & ICD-10 | February 27, 2013

The Centers for Medicare and Medicaid Services (CMS) will maintain their commitment to the current ICD-10-CM/PCS compliance date of October 1, 2014, according to a letter sent to AHIMA President Kathleen A. Frawley.

The letter was sent in response to AHIMA’s call for CMS to stand firm on its ICD-10 implementation date after more than 80 physician groups represented by the American Medical Association called on CMS in January to delay or abandon the ICD-10 conversion…

Susan Donaldson James reports for ABC News on DSM-5‘s ‘Somatic Symptom Disorder’:

Contributions from Allen Frances, MD, Joel E Dimsdale, MD (Chair, DSM-5 Somatic Symptom Disorder Work Group), Lori Chapo-Kroger (P.A.N.D.O.R.A), Suzy Chapman (Dx Revision Watch), Bridget Mildon (FND Hope) and Marianne Russo (The Coffee Klatch)

ABC News

New Psych Disorder Could Mislabel Sick as Mentally Ill

Susan Donaldson James | February 27, 2013

Critics worry that patients will be misdiagnosed as mentally ill and won’t get treatment, affecting mostly those with chronic and difficult to diagnose neurological disorders and multi-system diseases like ME/CFS, ones that are poorly understood and can take years to get medical answers.

“A lot of people will be written off as crocks — it’s just in their head,” said Dr. Allen Frances, who was chair of the task force that created the DSM-4 and professor emeritus of psychiatry at Duke University. “They won’t get the medical work-up they need.”

…But [SSD work group chair] Dimsdale defends the updated DSM…”If it doesn’t work, we’ll fix it in the DSM-5.1 or DSM-6.”

Robert Sibley, senior writer for Ottawa Citizen, comments on DSM-5‘s ”Somatic Symptom Disorder’:

Ottowa Citizen (and  a number of syndications)

Column: Is life itself a sickness in need of a cure?

Robert Sibley | February 20, 2013

…In a recent article, Postmedia’s Sharon Kirkey quotes a statement from the American Psychiatric Association, which will publish a new edition of the DSM in May: “Some patients with illnesses like heart disease or cancer will indeed experience thoughts, feelings or behaviours related to their illness that will be extreme or overwhelming.” These individuals “may qualify for an SSD diagnosis…”

Results of recent American Psychiatric Association Trustee elections:

Helio

APA releases election results

February 25, 2013

DSM-5 (published by American Psychiatric Publishing Inc.) is planned for release at the APA’s 166th Annual Meeting, in San Francisco (May 18-22).

Psychiatric News | February 15, 2013
Volume 48 Number 4 page 21-21
10.1176/appi.pn.2013.2b24

American Psychiatric Association
Annual Meeting Highlights

Sessions Will Provide In-Depth Look at New DSM

Kuhl Emily, Ph.D.

Sidney Zizook, M.D., who served as an advisor to the DSM-5′s Mood Disorder Work Group, defends the removal of the DSM ‘bereavement exclusion’:

Scientific American

Getting Past the Grief over Grief

Sidney Zisook | February 25, 2013

These days, I get a lot of grief about grief. I am part of the work group that changed some of the ways that grief and clinical depression are described and differentiated in the new Diagnostic and Statistical Manual of Mental Disorders, typically referred to as DSM-5. That has led to a lot of conversations with colleagues who are upset about bereavement…

Kupfer DJ, Regier DA, et al in JAMA ONLINE FIRST

JAMA ONLINE FIRST

DSM-5—The Future Arrived FREE ONLINE FIRST

David J. Kupfer, MD; Emily A. Kuhl, PhD; Darrel A. Regier, MD, MPH

Author Affiliations: University of Pittsburgh School of Medicine, Department of Psychiatry, Western Psychiatric Institute and Clinic, Pittsburgh, Pennsylvania (Dr Kupfer); and American Psychiatric Institute for Research and Education, Division of Research, American Psychiatric Association, Arlington, Virginia (Drs Kuhl and Regier).

JAMA. 2013;():1-2. doi:10.1001/jama.2013.2298.
Published online February 25, 2013

Jerome C. Wakefield, PhD, DSW, for Psychiatry Weekly, on the DSM ‘bereavement exclusion’ issue:

Remember the Bereavement Exclusion

Psychiatric Weekly

Jerome C. Wakefield, PhD, DSW | February 18, 2013

School of Social Work, Department of Psychiatry; New York University, NY

First published in Psychiatry Weekly, Volume 8, Issue 4, February 18, 2013

Update on ICD-11 Beta draft: Bodily Distress Disorder

Updates on ICD-11 Beta draft: Bodily Distress Disorder (proposed for ICD-11 Chapter 5: Mental and behavioural disorders); Chronic fatigue syndrome; Postviral fatigue syndrome; Benign myalgic encephalomyelitis (Chapter 6: Diseases of the nervous system)

Post #218 Shortlink: http://wp.me/pKrrB-2Bg

Dr Elena Garralda presentation slides:

http://www.rcpsych.ac.uk/pdf/Garralda%20E.pdf

or open here: Click link for PDF document    Garralda presentation Somatization in Childhood

Slide 1

Somatization in childhood

The child psychiatrist’s concern?

Elena Garralda

CAP Faculty Meeting, RCPsych Manchester, September 2012

Slide 11

New ICD-11 and DSM-V classifications

. Somatoform disorders >>>
– Bodily distress syndrome (ICD-11)
– Complex Somatic symptom disorder (DSM-V)

[Preceded by downward pointing arrow]

“Unexplained” or “functional” medical symptoms (CFS, fibromyalgia, irritable bowel syndrome)

[Preceded by upward pointing arrow]

Physical complaint (s)
with subjective distress/preoccupation ++,
illness beliefs impairment
health help seeking

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Notes on ICD-11 Beta drafting platform and DSM-5 draft by Suzy Chapman for Dx Revision Watch:

These notes may be reposted, if reposted in full, source credited, link provided, and date of publication included.

January 6, 2013

1] The publicly viewable version of the ICD-11 Beta drafting platform can be accessed here:
Foundation view: http://apps.who.int/classifications/icd11/browse/f/en
Linearization view: http://apps.who.int/classifications/icd11/browse/l-m/en

2] The various ICD-11 Revision Topic Advisory Groups are developing the Beta draft on a separate, more complex platform accessible only to ICD-11 Revision.

3] The ICD-11 Beta draft is a work in progress and not scheduled for completion until 2015/16. When viewing the public version of the Beta draft please note the ICD-11 Revision Caveats. Note also that not all proposals may be retained following analysis of the field trials for ICD-11 and ICD-11-PCH, the abridged Primary Care version of ICD-11:
http://apps.who.int/classifications/icd11/browse/Help/Get/caveat/en

4] The Bodily Distress Disorders section of the ICD-11 Beta draft Chapter 5 can be found here:
http://apps.who.int/classifications/icd11/browse/f/en#/http%3a%2f%2fwho.int%2ficd%23F45
http://apps.who.int/classifications/icd11/browse/l-m/en#/http%3a%2f%2fwho.int%2ficd%23F45

According to the public version of the ICD-11 Beta drafting platform, the existing ICD-10 Somatoform Disorders are currently proposed to be replaced with Bodily Distress Disorders, and Psychological and behavioural factors associated with disorders or diseases classified elsewhere, not with Bodily distress syndrome as Dr Garralda has in her slide presentation.

The following proposed ICD-11 categories are listed as child categories under parent, Bodily Distress Disorders, and Psychological and behavioural factors associated with disorders or diseases classified elsewhere:

EC5 Mild bodily distress disorder
EC6 Moderate bodily distress disorder
EC7 Severe bodily distress disorder
EC8 Psychological and behavioural factors associated with disorders or diseases classified elsewhere

There are no Definitions nor any other descriptors populated for the proposed, new ICD categories EC5 thru EC7.

EC8 is a legacy category from ICD-10 and has some populated content imported from ICD-10.

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These earlier ICD-11 Beta draft Somatoform Disorders categories appear proposed to be eliminated and replaced with the four new categories EC5 thru EC8, listed above:

Somatization disorder [F45.0 in ICD-10]
Undifferentiated somatoform disorder [F45.1 in ICD-10]
Somatoform autonomic dysfunction [F45.3 in ICD-10]
Persistent somatoform pain disorder [F45.4 in ICD-10]
    > Persistent somatoform pain disorder
    > Chronic pain disorder with somatic and psychological factors [Not in ICD-10]
Other somatoform disorders [F45.8 in ICD-10]
Somatoform disorder, unspecified [F45.9 in ICD-10]

5] The existing ICD-10 Chapter V category Neurasthenia [ICD-10: F48.0] is no longer accounted for in the public version of the ICD-11 Beta draft. I have previously reported that for ICD-11-PHC, the Primary Care version of ICD-11, the proposal is to eliminate the term Neurasthenia.

(I cannot confirm whether the currently omission of Neurasthenia from the Beta draft is due to oversight or because ICD-11 Revision’s intention is that Neurasthenia is also eliminated from the main ICD-11 classification.)

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6] I have previously reported that for ICD-11-PHC, the abridged, Primary Care version of ICD-11, the proposal, last year, was for a disorder section called Bodily distress disorders, under which would sit Bodily stress syndrome [sic].

This category is proposed for ICD-11 Primary Care version to include “milder somatic symptom disorders” as well as “DSM-5’s Complex somatic symptom disorder” and would replace “medically unexplained somatic symptoms.”

7] Dr Garralda lists Complex Somatic symptom disorder (DSM-V) on Slide 11 of her presentation.

The manual texts for the next edition of DSM are in the process of being finalized for a projected release date of May 2013. The next edition of DSM will be published under the title DSM-5 not DSM-V . The intention is that once published, updates and revisions to DSM-5 will be styled: DSM-5.1, DSM-5.2 etc.

When the third draft of DSM-5 was released in May 2012, the proposal was to merge Complex Somatic Symptom Disorder with Simple Somatic Symptom Disorder and to call this hybrid category Somatic Symptom Disorder.

This would mean that this new disorder has the same name as the overall disorder section it sits under, which replaces DSM-IV’s Somatoform Disorders.

As any subsequent changes to draft criteria sets following closure of the third stakeholder review are embargoed, I cannot confirm whether the SSD Work Group has decided to rename this category to Somatic symptom Disorder or retain the original term, Complex Somatic Symptom Disorder, the term used by Dr Garralda in her presentation.

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8] Turning from ICD-11 Beta draft Chapter 5 Mental and behavioural disorders to Chapter 6 Diseases of the nervous system:

As previously reported, Chronic fatigue syndrome is listed under Diseases of the nervous system in the Foundation View. There is no listing for Chronic fatigue syndrome in the Linearization View nor is the term listed in the PDF for Chapter 6, that is available to those who are registered with ICD-11 Beta draft for access to additional content:

http://apps.who.int/classifications/icd11/browse/f/en#http%3a%2f%2fwho.int%2ficd%23G93.3

Documentation from the ICD-11 iCAT Alpha draft dating from May 2010, implies that the intention for ICD-11 is a change of hierarchy for the existing ICD-10 Title term Postviral fatigue syndrome.

In the ICD-11 Beta draft, Chronic fatigue syndrome (which was listed only within the Index volume of ICD-10 and not listed in Volume 2: The Tabular List) appears to be elevated to ICD Title term status, with potentially up to 12 descriptive parameters yet to be completed and populated in accordance with the ICD-11 “Content Model”.

But the current proposed hierarchical relationship between PVFS and CFS for ICD-11 remains unconfirmed.

See image for documentation from the iCAT Alpha drafting platform, from May 2010:

https://dxrevisionwatch.com/wp-content/uploads/2010/06/change-history-gj92-cfs.png

There is no discrete ICD Title term displaying for Postviral fatigue syndrome in either the ICD-11 Beta Foundation View or Linearization View.

Neither is there any discrete ICD Title term displaying for Benign myalgic encephalomyelitis in either the Foundation View or Linearization View.

Benign myalgic encephalomyelitis appears at the top of a list of terms under “Synonyms” in the CFS description. [The hover text over the asterisk at the end of “Benign myalgic encephalomyelitis” reads, “This term is an inclusion term in the linearizations.”]

Postviral fatigue syndrome is also listed under “Synonyms” along with a number of other terms imported from other classification systems.

Included in this list under “Synonyms” are “chronic fatigue syndrome nos” and “chronic fatigue, unspecified,” both of which appear to have been sourced from the as yet to be implemented, US specific, ICD-10-CM.

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At some recent, unspecified date, a Definition has been inserted for ICD-11 Title term Chronic fatigue syndrome into the previously empty Definition field. An earlier Definition was removed when the Alpha draft was replaced with the Beta draft but can be seen in this screenshot, here, from June 2010:

https://dxrevisionwatch.com/wp-content/uploads/2010/05/2icatgj92cfsdef.png

The current Definition reads (and be mindful of the ICD-11 Caveats):

“Chronic fatigue syndrome is characterized by extreme chronic fatigue of an indeterminate cause, which is disabling andt [sic] does not improve with rest and that is exacerbated by physical or mental activity.”

There are no Definition fields for Benign myalgic encephalomyelitis or Postviral fatigue syndrome as these terms are listed under “Synonyms” to ICD-11 Title term, Chronic fatigue syndrome.

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Since one needs to be mindful of the ICD-11 Caveats and as the Chair of Topic Advisory Group for Neurology has failed to respond to a request for clarification of the intention for these three terms and the proposed ICD relationships between them, I am not prepared to draw any conclusions from what can currently be seen in the Beta drafting platform.

I shall continue to monitor the Beta draft and report on any significant changes.

For definitions of “Synonyms,” “Inclusions,” “Exclusions” and other ICD-11 terminology see the iCAT Glossary:
http://apps.who.int/classifications/apps/icd/icatfiles/iCAT_Glossary.html

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Related material:

http://www.rcpsych.ac.uk/pdf/8%20Ash%20IC2012.pdf

Presentation slides: Medically Unexplained Symptoms pages

Dr Graham Ash, Lancashire Care NHS Foundation Trust

Website pages featured in the slide presentation:

Medically Unexplained Symptoms

http://www.rcpsych.ac.uk/expertadvice/improvingphysicalandmh/aboutthissite.aspx

Dx Revision Watch Post, June 26, 2012: ICD-11 Beta drafting platform: Update (2): Neurasthenia, Postviral fatigue syndrome (PVFS), Benign myalgic encephalomyelitis (ME), Chronic fatigue syndrome (CFS), Fibromyalgia (FM), Irritable bowel syndrome (IBS): http://wp.me/pKrrB-2mC

Response to Recommendations from November 2011 CFSAC meeting

Response to Recommendations from November 2011 CFSAC meeting

Post #203 Shortlink: http://wp.me/pKrrB-2ur

The response from the Assistant Secretary for Health to Recommendations from the November 2011 CFSAC meeting is now available on the CFSAC website at: http://1.usa.gov/OghDXF

http://www.hhs.gov/advcomcfs/asst-sect-letter2012.pdf

or open here  asst-sect-letter2012

Text:

DEPARTMENT OF HEALTH & HUMAN SERVICES Office of the Secretary

Office of the Assistant Secretary for Health Washington, D.C. 20201
AUG -3 2012
Gailen Marshall Jr., MD, PhD

Chair, Chronic Fatigue Syndrome Advisory Committee
Professor and Chair Professor of Medicine and Pediatrics
The University of Mississippi Medical Center 2300
North State Street, N416 Jackson, MS 39216-4505

Dear Dr. Marshall:

I have received the recommendations developed by the Chronic Fatigue Syndrome Advisory Committee (CFSAC) during its November 8-9, 2011, meeting. The advice and counsel provided by CFSAC serves as a valuable resource in the Department of Health and Human Services’ (HHS) efforts to properly address the issues and concerns pertaining to chronic fatigue syndrome.

Since the meeting the Department has carefully considered your recommendations. Dr. Nancy Lee, the Designated Federal Officer for CFSAC, has worked collaboratively with the ex officio representatives to the committee to provide responses to the recommendations developed at the meeting. The enclosed document contains information about activities currently undertaken by HHS to work with public health experts and members of the chronic fatigue syndrome community to increase knowledge and provide a better understanding of this debilitating health condition.

I have shared the committee’s recommendations with Secretary Kathleen Sebelius.

The Department is committed to addressing this condition. I commend you and your committee members for the important work you do.

Sincerely yours,
/s/Howard K. Koh
Howard K. Koh, M.D., M.P.H. Assistant Secretary for Health

Enclosure

cc: Dr. Christopher R. Snell
U.S. Public Health Service

RESPONSES TO RECOMMENDATIONS FROM THE CHRONIC FATIGUE SYNDROME ADVISORY COMMITTEE (CFSAC)

REF: November 8-9, 2011 CFSAC Meeting

Recommendation 1: This recommendation addresses the process by which CFSAC transmits recommendations to the Secretary and the Secretary communicates back to CFSAC whether or not a recommendation was acted upon. CFSAC recommends that this process be transparent and clearly articulated to include regular feedback on the status of the Committee’s recommendations. This communication could originate directly from the Office of the Secretary or be transmitted via the relevant agency or agencies.

Procedures are in place to ensure that recommendations made by federal advisory committees are properly handled. The CFSAC charter stipulates that the Committee provides advice and recommendations to the Secretary, through the Assistant Secretary for Health (ASH). Initially, the CFSAC recommendations are sent to the ASH for review. After reviewing the recommendations, the ASH forwards them to appropriate officials within the Office of the Secretary and the Operating and/or Staff Divisions that may be impacted by the Committee’s recommendations. A letter is sent to acknowledge receipt of the recommendations. A response may be prepared to accompany the letter which describes any actions that the Department may take in response to the recommendations made by the Committee. All pertinent information about the recommendations is provided to the designated Federal officer (DFO). The DFO then provides the information to the Chair and the Committee.

Recommendation 2: CFSAC recommends to the Secretary that the NIH or other appropriate agency issue a Request for Application (RFA) for clinical trials research on chronic fatigue syndrome/myalgic encephalomyelitis (ME/CFS).

The National Institutes of Health (NIH) funds research on myalgic encephalomyelitis/chronic fatigue syndrome (ME/CFS); investigators are encouraged to submit proposals for ME/CFS research, including clinical trials, through two funding announcements that are currently open for submission of applications. The next deadline for receipt of applications is October 24, 2012. In fiscal year 2011, NIH funded two applications for clinical trials on ME/CFS. NIH has received few applications proposing ME/CFS research, and even fewer applications proposing ME/CFS clinical trials. It is unclear whether the paucity of ME/CFS clinical trial applications reflects the current status of the field or an acknowledgement that clinical trials are difficult to design for a complex and multi-faceted illness. Clinical trials are challenging to design and conduct for all diseases, with basic requirements of a well-defined patient population, valid measurement instruments, appropriate safeguards for subjects, and generalizability of the clinical trial outcomes to the larger affected patient population. NIH is taking action to stimulate ME/CFS research across NIH through the regular monthly meetings of the Trans-NIH ME/CFS Working Group (WG). The WG discusses the current status of ongoing research on ME/CFS and proposes methods to increase the number and quality of research applications submitted to NIH ranging from preclinical research to clinical trials. In addition, the WG is focusing on the recommendations from the April 2011 State of the Knowledge Workshop on ME/CFS to develop priorities. The outcome from these planning sessions will suggest a range of activities and research.

Recommendation 3: CFSAC would like to encourage and support the creation of the DHHS Interagency Working Group on Chronic Fatigue Syndrome and ask this group to work together to pool resources that would put into place the “Centers of Excellence” concept that has been recommended repeatedly by this advisory committee. Specifically, CFSAC encourages utilizing HHS agency programs and demonstration projects, available through the various agencies, to develop and coordinate an effort supporting innovative platforms that facilitate evaluation and treatment, research, and public and provider education. These could take the form of appropriately staffed physical locations, or be virtual networks comprising groups of qualified individuals who interact through a variety of electronic media. Outreach and availability to underserved populations, including people who do not have access to expert care, should be a priority in this effort.

HHS leadership has identified the need for a Department-wide plan to address ME/CFS. The Department established the HHS Ad Hoc Workgroup on ME/CFS to develop a plan and to identify opportunities for interagency collaboration. The HHS ME/CFS plan will highlight recently initiated programs and future agency-specific and cross-agency activities. In developing the report, the Ad Hoc Workgroup will consider recommendations made by CFSAC. After completion, the ME/CFS plan will be posted on the CFSAC website. The DFO, Nancy C. Lee, M.D. is responsible for providing leadership and coordination for development of the HHS ME/CFS report.

Recommendation 4: This multi-part recommendation pertains to classification of CFS in ICD classification systems:

a) CFSAC considers CFS to be a multi-system disease and rejects any proposal to classify ME/CFS as a psychiatric condition in the U.S. disease classification systems.

b) CFSAC rejects the current classification of ME/CFS in Chapter 18 of ICD-9-CM under R53.82, chronic fatigue unspecified, chronic fatigue syndrome, not otherwise specified.

c) CFSAC continues to recommend that ME/CFS should be classified in ICD-IO-CM in Chapter 6 under Diseases of the Nervous System at G93.3 in line with ICD-IO, the World Health Organization, and ICD-I-CA [sic], the Canadian Clinical Modification and in accordance with CFSAC’s recommendations of August 2005 and May 2011. CFSAC rejects CDC’s National Center for Health Statistics (NCHS) Option 2 and recommends that ME/CFS remain in the same code and the same subcode as myalgic encephalomyelitis because CFS includes both viral and non-viral triggers.

d) CFSAC recommends that an “excludes one”* be added to G93.3 for chronic fatigue, R53.82, and neurasthenia, F48.8. CFSAC recommends that these changes be made in ICD-10-CM prior to its rollout in 2013.**

[*Ed: Should read “Excludes 1”. For definitions for “Excludes1″ and “Excludes2″ see Post #118]

[**Ed: On August 3, HHS announced Final Rule to delay compliance date for ICD-10-CM/PCS to October 1, 2014.]

Development and implementation of the guidelines for the lCD-10 fall within HHS under the purview of the Centers for Disease Control and Prevention (CDC) and the Centers for Medicare and Medicaid Services. Use of the revised codes will provide robust and specific data that will improve patient care and enable the international comparability of health care data. On February 16, 2012, the Department issued a press release announcing that HHS would initiate a process to postpone the date that certain health care entities must comply with the ICD-10.

A proposal to change the classification of ME/CFS in ICD-10-CM was presented at the September 2011 Coordination and Maintenance (C & M) Committee/CDC/NCHS; a subsequent proposal was received on January 12, 2012 and will be presented at the September 19, 2012 C & M meeting for additional discussion.

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Related posts

Notice of Meeting of the ICD-9-CM Coordination and Maintenance Committee

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

Extracts: ICD-9-CM Coordination and Maintenance Committee Meeting Summary document (CFS coding)

Extracts: ICD-9-CM Coordination and Maintenance Committee Meeting September 14, 2011 (Coding of CFS in ICD-10-CM)