PVFS, ME and CFS in classification and terminology systems: notes for the future

Post #355 Shortlink: https://wp.me/pKrrB-4Yv

In 2002, I set up FreeMEuk — a Yahoo Group support and information exchange for patients with ME, CFS, and for carers, like myself. In 2007, I launched ME agenda to provide patients, carers and advocates with information, resources and commentary on the political issues affecting the lives of myalgic encephalomyelitis (ME) patients in the UK.

In January 2010, I created this site specifically to monitor and report on the development of the American Psychiatric Association’s DSM-5, the development of the World Health Organization’s ICD-11 and on other classification and terminology systems. Where appropriate, I have galvanized stakeholders to participate in review and comment exercises or co-ordinated other forms of response.

Down the years, I’ve undertaken numerous short and long-term ad hoc projects, advised others on technical matters relating to classification and terminology systems, submitted and collaborated in the submission of proposals, briefed politicians and patient organizations and kept patient forums up to date with key developments.

Today I am retiring after 17 years of advocacy work.

My sites will remain online for the foreseeable future. Over the coming months I shall be carrying out some housekeeping on this site to remove or archive older, less relevant content.

Classification and terminology systems are going to need continued monitoring; where required, input from stakeholder groups — clinicians, researchers, health practitioners and professional body allies, social workers, disability lawyers and advocacy organizations will need to be co-ordinated.

Where no process for public stakeholder input currently exists, channels of direct communication will need to be opened with the agencies responsible for the development and management of these systems and collaborative dialogues established.

WHO, for example, ostensibly gives more consideration to evidence based submissions supported by rationales, international consensus and input from clinical and professional bodies — has scant regard for patient opinion and none whatsoever for petitions or mass mailings — the latter and similar types of “action” will only undermine the careful work and discourse that I and others have fostered.

All these systems will require regular monitoring:


DSM-5 published in May 2013; it has an update process which reviews formal submissions for changes to criteria, related texts, assessment measures or corrections. DSM-5 also absorbs relevant coding changes in the annual FY releases of the U.S. specific ICD-10-CM. Approved proposals are posted for a 45 day stakeholder comment period. For example, in 2015, an edit in the text for Somatic symptom disorder¹ was approved for implementation and the revised text published in the DSM-5 Update Supplement.



Member states using the WHO’s ICD-10 don’t all use the same version (or the most recent version), for example, NHS England currently mandates the use of ICD-10 Version: 2015, not Version: 2016. WHO has said that the final update to ICD-10 will be Version: 2019. This final release is understood to have been prepared but is not currently available on the ICD-10 Browser platform.


The U.S. uses ICD-10 for reporting mortality and developed a “clinical modification” of ICD-10 (called ICD-10-CM) for morbidity. A new release of ICD-10-CM is posted on the CDC website annually, in June.

There are two public NCHS/CDC Coordination and Maintenance Committee meetings a year through which proposals for changes to the ICD-10-CM can be submitted for discussion (in March and September) followed by a stakeholder comment period.

At the September 12, 2018 C & M Committee meeting, proposals for changes to the existing coding of R53.82 Chronic fatigue syndrome NOS; G93.3 Postviral fatigue syndrome, Benign myalgic encephalomyelitis; and a second option for addition of the SEID term were presented for consideration and public comment¹. Whilst no changes for these codes were approved for implementation in the FY 2020 ICD-10-CM release, this topic will need continued monitoring as it may be revisited at a future C & M Committee meeting for presentation of revised proposals.

1 ICD-10-CM Coordination and Maintenance Committee Meeting, September 11-12, 2018, Diagnosis Agenda Part 2

Other country specific clinical modifications of ICD-10:

Around 25 member states are also using a modification of the WHO’s ICD-10. For example: Canada (ICD-10-CA); Germany (ICD-10-GM); Australia (ICD-10-AM). Belgium, Luxembourg and Spain use ICD-10-CM; Ireland and Slovenia use ICD-10-AM.

Countries using modifications of ICD-10 have individual update cycles and varying policies around public stakeholder input and review. Some countries post their Tabular List and Index modifications in the public domain; others are available only under licence, for example, Australia’s ICD-10-AM isn’t publicly available. The coding, hierarchy and chapter location of the PVFS, BME and CFS terms differs between some of the clinical modifications, while others remain consistent with the structure of the WHO’s ICD-10.

This table from the eHealth DSI Semantic Knowledge Base project compiles information provided from a number of member states on their use of ICD (or a modification of ICD) and their plans regarding potential future implementation of ICD-11. Information has been provided by: Austria, Belgium, Croatia, Cyprus, Czech Republic, Estonia, France, Germany, Greece, Hungary, Ireland, Italy, Luxenbourg, Malta, Netherlands, Portugal, Slovenia and Spain: Current status of the use of ICD by eHDSI deploying countries (2018)


SNOMED CT is a comprehensive clinical terminology system used in electronic patient health records. SNOMED CT maps to ICD-10 and there is a SNOMED CT to ICD-11 Mapping Project in progress.

SNOMED International has thirty-nine member countries. There is a SNOMED CT International Edition, for which two releases are issued per year (in January and July). There are a number of country specific national editions which release twice yearly updates on a staggered schedule. 12 of these national editions can be viewed on the SNOMED CT Browser platform.

SNOMED CT national editions absorb the changes in the most recent release of the International Edition but they can also include additional country specific terms. For example, the UK Edition has a unique Concept term: Medically unexplained symptoms (SCTID: 887761000000101). Prior to March 2019, the SNOMED CT Netherlands Edition had retained the term “neurasthenie” under Synonyms to Chronic fatigue syndrome, although the Concept term: Neurasthenia (SCTID: 268631001) and some associated codes had been retired from the International Edition and from all other national editions, some years ago. Following a request supported by a rationale, the term “neurasthenie” has now been removed from the Netherlands Edition.

The SNOMED CT Concept term for Chronic fatigue syndrome is SCTID 52702003 Chronic fatigue syndrome (disorder). Benign myalgic encephalomyelitis; and Myalgic encephalomyelitis are included as Synonym terms.

Following a successful submission in February 2018 for the addition of a new parent, SCTID: 52702003 Chronic fatigue syndrome (disorder) has been assigned under parent: SCTID: 118940003 Disorder of nervous system (disorder) since the July 2018 release of the SNOMED CT International Edition. This change of parent has been incorporated into the national editions.

The International Edition and the national editions of SNOMED CT will need monitoring twice yearly for changes and additions to their content.


On May 25, 2019, the 72nd World Health Assembly voted unanimously to adopt the ICD-11. The earliest date from which member states can start using the ICD-11 code sets for reporting data is January 1, 2022. Countries are beginning to evaluate the new edition and develop road maps but even early implementers are anticipated to take several years to prepare their health systems for migration. There is no mandatory implementation date and countries will transition to ICD-11 at their own pace and according to their resources and requirements. For some years to come, WHO will be accepting data reported using both ICD-10 and ICD-11 code sets.

ICD-11 update and maintenance: The current release of ICD-11 (Version 04/2019) on the Blue ICD-11 MMS platform is a stable release but an update and maintenance cycle is already in place.

The various ICD-11 Topic Advisory Groups and sub working groups, the Revision Steering Group and the Joint Task Force have all been sunsetted. WHO is now advised on how to process proposals for changes to ICD-11 by the Family of International Classifications Network (WHO-FIC); the Classifications and Statistics Advisory Committee (CSAC); the Medical and Scientific Advisory Committee (MSAC); the Mortality and Morbidity Reference Groups; and the Functioning and Disability Reference Group.

Updates that impact on international reporting (the 4 and 5-digit structure of the stem codes) will be published every five years. Updates at a more detailed level can be published at annual rates. Additions to the ICD-11 index can be done on an ongoing basis. (There are currently in the region of 1200 unprocessed proposals waiting to be processed, with new proposals being submitted daily by WHO, professional bodies and other stakeholders.)

PVFS, BME, CFS: In a decision supported by the MSAC and CSAC committees, WHO rightly rejected the proposal of Dr Tarun Dua/Topic Advisory Group Neurology to delete the G93.3 legacy terms from the Diseases of the nervous system chapter and reclassify these terms in the Symptoms, signs chapter, under Symptoms, signs or clinical findings of the musculoskeletal system.

All three terms have been retained under their legacy chapter, under parent class: Other disorders of the nervous system, with 8E49 Postviral fatigue syndrome retained as the Concept Title. Benign myalgic encephalomyelitis; and chronic fatigue syndrome are both specified as Inclusion terms. Reciprocal exclusions for MG22 Fatigue were submitted for and approved.

The Proposal Mechanism platform for ICD-11 will need constant surveillance: there are currently no unprocessed proposals pending review for PVFS, BME and CFS. To date, WHO has rejected proposals for deprecation of the word “Benign” from Benign myalgic encephalomyelitis. This will need pursuing.

BDD: A proposal submitted by a third party in April 2017 for Deletion of 6C20 Bodily distress disorder has remained under review with the CSAC committee. According to WHO admins, in June 2019: “This proposal is being sent to MSAC to ensure the precedent decision on this issue still stands. Team3 WHO 2019-Jun-12 – 16:40 UTC”

(In February 2019, my own recommendations for 6C20 Bodily distress disorder had been marked as rejected by a different WHO admin team, with the comment: “This proposal has been extensively discussed by WHO and its advisory committees. There is no new scientific evidence to support this proposal and it will not be further processed. Team 2 WHO 2019-Feb-26 – 23:04 UTC)

On December 02, 2019 I submitted a new proposal and rational for adding exclusions for PVFS; BME; and CFS under 6C20 Bodily distress disorder. The WHO approved and implemented my proposal on January 17, 2020.

For copy of my rationale in support of this new proposal see: http://bit.ly/2NL0lX5

For more information on approved and rejected proposals see: Status of ICD-11 processed proposals v5 (updated to reflect implementation of exclusions under BDD).

Clinical modifications of ICD-11:

It is understood that the WHO would prefer to limit the development of national modifications and that policies around the licensing of ICD-11 are still being formulated. Countries developing modifications of ICD-11 will need surveillance.

See post World Health Assembly adopts ICD-11: When will member states start using the new edition? for more information on country plans.

See Presentation slides #36-38 for more information on licensing and the development of country modifications: Insights into the Next Revision: Like Texas, Everything is Bigger in ICD-11, Kathy Giannangelo, RHIA, CCS, CPHIMS, FHIMA, Texas Health Information Management Association.

ICD-11 and the CDDG guideline for mental disorders:

For ICD-11, the WHO Department of Mental Health and Substance Abuse has developed the “Clinical Descriptions and Diagnostic Guidelines (CDDG) for ICD‐11 Mental, Behavioural and Neurodevelopmental Disorders” (an equivalent publication to ICD-10’s “Blue Book”).

The CDDG provides expanded clinical descriptions, essential (required) features, boundaries with other disorders and normality, differential diagnoses, additional features, culture-related features and codes for all mental and behavioural disorders commonly encountered in clinical psychiatry; it is intended for mental health professionals and for general clinical, educational and service use.

WHO has said it plans to release the CDDG “as soon as possible” after WHA’s adoption of ICD-11. But it remains unclear whether the CDDG has been finalized or if it will be released this month, later this year or next year. See this post Clinical Descriptions and Diagnostic Guidelines (CDDG) for ICD‐11 Mental, Behavioural and Neurodevelopmental Disorders for more information.

Whilst clinicians have been able to register to review and provide feedback, no draft texts for the CDDG have been made available for public stakeholder scrutiny and comment and I have not had access, for example, to the most recent draft for the clinical descriptions and diagnostic guidelines for ICD-11’s Bodily distress disorder.

ICD-11 and the ICD-11 PHC:

Also under development is the WHO’s ICD-11 PHC — a clinical guideline written in simpler language to assist non-mental health specialists, especially primary care practitioners and non medically trained health workers, and also intended for use in low resource settings and low- to middle-income countries, with the diagnosis and management of common mental disorders. It comprises 27 mental disorders and contains no other disorders or diseases. Like the ICD-10 PHC (1996), this revised diagnostic and management guideline will not be a mandatory classification for member states.

For the mandatory core ICD-11 classification, WHO is going forward with the SSD-like Bodily distress disorder (BDD).

But the ICD-11 PHC is proposed to include a disorder category called “Bodily Stress Syndrome (BSS)” that has been adapted from the Fink et al (2010) Bodily distress syndrome (BDS). See Comparison of SSD, BDD, BDS, BSS in classification systems, July 2018.

Under exclusions and differential diagnoses for BSS, certain psychiatric and general medical diagnoses have to be excluded but CFS, ME; IBS; and FM appear not to be specified as exclusions. See this post Clinical Descriptions and Diagnostic Guidelines (CDDG) for ICD‐11 Mental, Behavioural and Neurodevelopmental Disorders for more information.

It’s not known when this guideline is expected to be finalized and made available for download. The ICD-11 PHC has not been developed on a publicly accessible platform and draft texts are not available for public stakeholder review and comment. This non mandatory 27 mental disorder guideline needs close scrutiny.


The WONCA developed and WHO endorsed, International Classification of Primary Care (ICPC-2) is under revision for ICPC-3.

ICPC-2 is available in 34 countries; used in primary care in 27 countries and is mandatory in 6 EU countries, eg the Netherlands. The content of ICPC-3 will be linked to relevant classifications, such as ICD-10, ICD-11, ICF, ICHI, DSM-5, clinical terminologies such as SNOMED-CT, but also to previous versions of ICPC.

The draft content for ICPC-3 is not being developed on a publicly accessible platform and it’s unclear whether any form of stakeholder review will be undertaken or at what point.

Caveat: This ICPC-3 roadmap on an ICPC-3 Working Group platform may have been revised since it was posted: ICPC-3 Roadmap Milestones August 28, 2018.

Dr Marianne Rosendal (Aarhus University), who has published with Prof Per Fink, is the European representative on WONCA’s International Classification Committee and a member of the revision committee for ICPC-2, as is the U.S.’s, Dr Michael Klinkman. ICPC-2 meeting summary documents dating from 2010/2011 indicate that Dr Rosendal has discussed the potential for inclusion of a Bodily distress syndrome or similar disorder concept in the ICPC-3. Prof Per Fink is likely to be lobbying hard for its inclusion. The development of ICPC-3 will need very close monitoring.


Comparison of Classification and Terminology Systems, Chapman & Dimmock, July 2018

Comparison of SSD, BDD, BDS, BSS in classification systems, Chapman & Dimmock, July 2018

Post: ICD-11 implementation package, June 06, 2019

Post: World Health Assembly adopts ICD-11: When will member states start using the new edition? June 17, 2019

Post: Clinical Descriptions and Diagnostic Guidelines (CDDG) for ICD‐11 Mental, Behavioural and Neurodevelopmental Disorders, June 28, 2019

Insights into the Next Revision: Like Texas, Everything is Bigger in ICD-11, Kathy Giannangelo, RHIA, CCS, CPHIMS, FHIMA, Texas Health Information Management Association


ICD-10-CM Release for 2014 now available

Post #270 Shortlink: http://wp.me/pKrrB-3iT

ICD-10-CM Release for 2014 now available

Prior to implementation, the codes in ICD-10-CM are not valid for any purpose or use.

The World Health Organization’s (WHO) International Classification of Diseases (ICD-10) was published in 1992 and is used in over a hundred countries worldwide.

A number of countries have been authorized by WHO to develop “Clinical Modifications” – adaptations of ICD-10 for country specific use. These differ in the number of chapters, codes and subcategories. Specific conditions are present in some adaptations but not all clinical modifications [1]. All modifications to the ICD-10 must conform to WHO conventions for ICD.

Canada uses an adaptation called ICD-10-CA, Australia uses ICD-10-AM, Germany uses ICD-10-GM and Thailand uses ICD-10-TM.

The U.S. lags behind most of the rest of the world and is still using a Clinical Modification of the WHO’s long since retired, ICD-9.

A U.S. specific adaptation of ICD-10 has been under development for a considerable length of time but is scheduled for implementation on October 1, 2014.

Transition to ICD-10-CM is required for everyone covered by the Health Insurance Portability Accountability Act (HIPAA).

Implementation schedules for Large Practices; Small and Medium Practices; Small Hospitals and Payers can be found on the CMS website, here: Implementation Timelines.

2014 release of ICD-10-CM

The 2014 release of ICD-10-CM is now available from the CDC website. It replaces the July 2012 release.

Prior to the implementation date of October 1, 2014, the codes in ICD-10-CM are not valid for any purpose or use.

The ICD-10-CM code set is currently subject to partial code freeze. For information on the code freeze see Partial Freeze of Revisions to ICD-9-CM and ICD-10-CM/PCS.

October 1, 2011 was the last major update of ICD-10-CM/PCS until October 1, 2015. Between October 1, 2011 and October 1, 2015, revisions to ICD-10-CM/PCS will be for new diseases/new technology procedures or minor revisions to correct any reported errors in these classifications. Regular (at least annual) updates to ICD-10-CM/PCS will resume on October 1, 2015.

Information on the ICD-9-CM and ICD-10-CM/PCS update and revision processes and the public NCHS/CDC Coordination and Maintenance Committee meetings can be found on this CDC page: Coordination and Maintenance Committee.

Downloading the ICD-10-CM code sets

The ICD-10-CM Preface, Guidelines, Tabular List, Index and associated documentation can be downloaded from this page: http://www.cdc.gov/nchs/icd/icd10cm.htm#10update.

The PDF of the Preface is in a single PDF file here: ICD-10-CM Preface 2014

The PDF of the Guidelines is in a single PDF file here: ICD-10-CM Guidelines

To access the PDFs for the ICD-10-CM Tabular List and Index, the files need extracting from Zip files from this link:

ICD-10-CM List of codes and Descriptions (updated 7/3/2013)

( ftp://ftp.cdc.gov/pub/Health_Statistics/NCHS/Publications/ICD10CM/2014/ )

Select this file, below, on the CDC site and open it. It is a large file of over 15MB so you will need to allow sufficient time for it to fully load:

06/19/2013 08:28AM 15,223,965 ICD10CM_FY2014_Full_PDF.zip

It will unpack these five PDF files, which can be opened and viewed in situ or saved:


or open unzipped PDF on Dx Revision Watch: ICD-10-CM 2014 Full Index

ICD10CM_FY2014_Full_PDF_EIndex   [401 KB]  [ICD-10-CM External Cause of Injuries Index]

ICD10CM_FY2014_Full_PDF_TableOfDrugs   [2,193 KB]

ICD10CM_FY2014_Full_PDF_TableOfNeoplasms   [646 KB]

ICD10CM_FY2014_Full_PDF_Tabular   [7, 398 KB]  [ICD-10-CM TABULAR LIST of DISEASES and INJURIES]

or open unzipped PDF on Dx Revision Watch: ICD-10-CM Tabular List

For five PDF files of Addenda go to this page:


and select this file:

06/19/2013 08:28AM 582,584 ICD10CM_FY2014_Addenda.zip

Comparison between classifications and codings in ICD-10-CM and ICD-10

The WHO’s ICD-10 Volume 1 The Tabular List isn’t made available as a PDF file but can be accessed on a searchable electronic browser platform here: ICD-10 Version: 2010.

The Tabular List for ICD-10 contains more textual descriptions for the categories in Chapter V (the mental and behavioural disorders chapter) than other chapters in ICD-10.

There are also two “speciality” volumes for ICD-10 Chapter V for Clinical descriptions and diagnostic guidelines (known as the “Blue Book”) and Diagnostic criteria for research (known as the “Green Book”).

The U.S. specific ICD-10-CM will not contain this depth of textual content within its Chapter 5.

CDC’s, Donna Picket, has confirmed that CMS/CDC does not plan to adapt the “Blue Book” specifically for U.S. use in conjunction with Chapter 5 of ICD-10-CM [2]. Nor are there plans for an official CMS/CDC crosswalk between ICD-10-CM’s Chapter 5 classifications and codes and those in ICD-10 Chapter V [3].

In the U.S., since 2003, the ICD-9-CM diagnostic codes have been mandated for third-party billing and reporting by HIPAA for all electronic transactions for billing and reimbursement. Following implementation on October 1, 2014, the ICD-10-CM codes sets will become mandatory.

This also applies to the coding of mental and behavioural disorders. APA’s DSM-IV disorder diagnoses are crosswalked to ICD-9-CM codes, or their nearest equivalent, for billing and reimbursement.

The DSM-5, published in May this year, includes the crosswalk codes for both the existing ICD-9-CM and the forthcoming ICD-10-CM codes.

For comparison between

ICD-10-CM Chapter 5 Mental, Behavioral and Neurodevelopmental disorders (F01-F99)

and ICD-10 Chapter V Mental and behavioural disorders (F00-F99) see the ICD-10 online browser or

The ICD-10 Classification of Mental and Behavioural Disorders Clinical descriptions and diagnostic guidelines (The “Blue Book”)

References and further resources

1. The development, evolution, and modifications of ICD-10: challenges to the international comparability of morbidity data. Jetté N, Quan H, Hemmelgarn B, Drosler S, Maass C, Moskal L, Paoin W, Sundararajan V, Gao S, Jakob R, Ustün B, Ghali WA; IMECCHI Investigators. Med Care. 2010 Dec;48(12):1105-10. doi: 10.1097/MLR.0b013e3181ef9d3e [PMID: 20978452].

The development, evolution and modifications of ICD-10: challenges to the international comparability of morbidity data: Nathalie Jetté MD, November 2009, Slide Presentation [5 MB].

2. Personal communication.

3. Personal communication.

4. Information for providers, payers and vendors on transition to ICD-10-CM can be found here on the CMS website.

5. DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services: ICD-10-CM/PCS MYTHS AND FACTS ICN 902143, April 2013.

6. American Psychological Association: Nine frequently asked questions about DSM-5 and ICD-10-CM, APA Practice staff answer questions about billing, determining diagnoses and more related to the two diagnostic classification systems. Practice Update, May 16, 2013.

7. American Psychiatric Association: Insurance Implications of DSM-5

8. AAPC What is ICD-9-CM?

Trouble with timelines (2) Might APA hold back DSM-5 in response to an October 2014 ICD-10-CM compliance date?

Trouble with timelines (2): Might APA hold back publication of DSM-5 in response to a firm October 2014 ICD-10-CM compliance date?

Post #200 Shortlink: http://wp.me/pKrrB-2sW

Update at August 17: Commentary on DSM-5 from One Boring Old Man: didn’t need to happen…

Update at August 16: Commentary on DSM-5 from One Boring Old Man: all quiet on the western front…


In Trouble with timelines (1): DSM-5, ICD-10-CM, ICD-11 and ICD-11-CM, on August 10, I wrote

With no changes to the published Timeline and no intimation of further delays, I’m assuming DSM-5 remains on target.

But it’s not necessarily a given that DSM-5 will be on the bookshelves for May 2013.

Roger Peele, M.D., D.L.F.A.P.A, has been a member of the DSM-5 Task Force since 2006. From 2007- 2010, Dr Peele was APA Trustee-At-Large; since 2010, Secretary to the APA Board of Trustees.

Dr Peele maintains a website at http://rogerpeele.com/index.asp providing clinical information for Montgomery County clinicians, resources for County residents and listing some of the initiatives taken relative to the American Psychiatric Association:


Writing just a few days after HHS Secretary’s announcement of intent to postpone the compliance date for adoption of ICD-10-CM/PCS codes sets for a further year, to October 1, 2014, Dr Peele informed his readers that the proposal to delay the compliance deadline

“…reduces some of the pressures to publish DSM-5 in 2013.”

In his post of February 23, Dr Peele goes on to say that a more certain answer was expected on February 28, but that remarks at the previous day’s American College of Psychiatrists meeting suggested the timing of DSM-5 for early 2013 was still on.

This suggests to me that if HHS decides not to take forward its proposal to delay ICD-10-CM compliance until October 1, 2014 but to stick with the original compliance date of October 1, 2013, that APA will still want to get its manual out several months ahead of the ICD-10-CM compliance deadline.

In order to meet a publication date of May 2013, APA says the final manual text will need to be with the publishers by December, this year. So unless HHS announces a decision within the next few weeks, APA isn’t going to have very much time left in which to dither over potentially shifting publication to 2014.

ICD-10-CM will be freely available online and is already accessible for pre implementation viewing. It’s the policy of WHO, Geneva, to make print versions of ICD publications globally available at reasonable cost. Although ICD-10-CM has been developed by US committees for US specific use, it’s not expected that print versions of ICD-10-CM will be as expensive as DSM-5.

DSM manuals are expensive; they are a commercial product generating substantial income for the APA’s publishing arm. APA will be looking to maximize sales and publication revenue and retain market share with this forthcoming edition.

There are already groups and petitions calling for the boycotting of DSM-5 in favour of using Chapter 5 of ICD-10-CM, when its code sets are operationalized.

So if ICD-10-CM is to be adopted by October 1, 2013, I cannot see APA and American Psychiatric Publishing not aiming to steal a march.

If, on the other hand, HHS were to announce shortly a firm rule that compliance for ICD-10-CM is being pushed back to October 2014, if DSM-5 Task Force and work groups are struggling to finalize the manual or having problems obtaining approval for some of their more contentious proposals from the various panels that are scrutinizing the near final draft, then delaying publication of DSM-5 to late 2013 or spring 2014 would provide APA with a window in which to complete its manual but still push it out ahead of ICD-10-CM.

Its PR firm can sell a publication delay to end-users as the APA’s taking the opportunity of postponement of ICD-10-CM compliance to allow more time for evaluation of DSM-5 field trial results, refinement of criteria or honing disorder description texts, and that a delay will better facilitate harmonization efforts with ICD-10-CM and ICD-11.

(ICD-10-CM is a modification of the WHO’s ICD-10 and has closer correspondence with DSM-IV than with DSM-5. Since 2003, ICD-9-CM diagnostic codes have been mandated by HIPAA for all electronic reporting and transactions for third-party billing and reimbursement and DSM-5 codes will need to be crosswalked to ICD-9-CM codes, for the remaining life of the ICD-9-CM. DSM-5 codes will also need to be convertible to ICD-10-CM codes for all electronic transactions.)

In a June 2011 presentation to the International Congress of the Royal College of Psychiatrists, APA President, John M. Oldham, MD, MS, spoke of “Negotiations in progress to ‘harmonize’ DSM-5 with ICD-11 and to ‘retro-fit’ these codes into ICD-10-CM” and that DSM-5 would need “to include ICD-10-CM ‘F-codes’ in order to process all insurance claims beginning October 1, 2011.”

With the drafting timelines for the three systems now so out of whack and a partial code freeze on ICD-10-CM, and with ICD-11 still at the Beta drafting stage, I can no longer be bothered to attempt to unscramble how alignment of the three systems [or best fit where no corresponding category exists] is going to dovetail, in practice, pre and post publication, or what the implications might be for the medical billing and coding industry, for clinicians and for patients.

Dr Peele then says

“Since ICD-11-CM is due in 2016, it may become appealing to the Feds to skip ICD-10-CM, and wait until 2016”

ICD-11-CM due in 2016?

Not so. It is the WHO’s ICD-11 that is aiming for readiness by 2016.

A misconception on the part of Dr Peele or wishful thinking?

It might suit the interests of APA and American Psychiatric Publishing, financially and politically, if ICD-10-CM were to be thrown overboard and instead, the US skip to a Clinical Modification of ICD-11, two or three years after a copy of its shiny new DSM-5 is sitting on every psychiatrist’s desk.

But that is not going to happen in 2016.

There is strong federal opposition, in any case, against leapfrogging over ICD-10-CM to a US modification of ICD-11:

Federal Register, January 16, 2009:

…We [ICD-9-CM Coordination and Maintenance Committee] discussed waiting to adopt the ICD-11 code set in the August 22, 2008 proposed rule (73 FR 49805)…

…However, work cannot begin on developing the necessary U.S. clinical modification to the ICD–11 diagnosis codes or the ICD–11 companion procedure codes until ICD–11 is officially released. Development and testing of a clinical modification to ICD–11 to make it usable in the United States will take an estimated additional 5 to 6 years. We estimated that the earliest projected date to begin rulemaking for implementation of a U.S. clinical modification of ICD–11 would be the year 2020.

The suggestion that we wait and adopt ICD–11 instead of ICD–10–CM and ICD–10–PCS does not consider that the alpha-numeric structural format of ICD–11 is based on that of ICD–10, making a transition directly from ICD–9 to ICD–11 more complex and potentially more costly. Nor would waiting until we could adopt ICD–11 in place of the adopted standards address the more pressing problem of running out of space in ICD–9–CM Volume 3 to accommodate new procedure codes…

And from a more recent Federal Register document:

Federal Register, April 17, 2012:

3. Option 3: Forgo ICD-10 and Wait for ICD-11

…The option of foregoing a transition from ICD-9 to ICD-10, and instead waiting for ICD-11, was another alternative that was considered. This option was eliminated from consideration because the World Health Organization, which creates the basic version of the medical code set from which all countries create their own specialized versions, is not expected to release the basic ICD-11 medical code set until 2015 at the earliest.

From the time of that release, subject matter experts state that the transition from ICD-9 directly to ICD-11 would be more difficult for industry and it would take anywhere from 5 to 7 years for the United States to develop its own ICD-11 CM and ICD-11-PCS versions.


From an interview with Christopher Chute, MD, Making the Case for the ICD-10 Compliance Delay April 4, 2012, by Gabriel Perna for Healthcare Informatics:

“…Chute is also adamant that there is no possible reason or possibility that the U.S. could just skip over ICD-10 right into ICD-11. Even with his ties to ICD-11, Chute says there it’s not realistic, nor is it plausible, to have seven-to-nine more years of ICD-9 codes, while the medical industry waits for the World Health Organization to finish drafting ICD-11 and then waits for the U.S. to adapt it for its own use.”

A recent article in the JOURNAL OF AHIMA/July 2012/Volume 83, Number 7 in response to Chute et al [1] suggests the earliest the US could move onto a CM of ICD-11 might be 2025, or 13 years from now.

So, if HHS were to announce, soonish, a final rule for an October 1, 2014 ICD-10-CM compliance date, it’s not totally out of the question, in my view, that APA (who might be struggling to complete the manual for December) may extend its publication date for a second time.



1] There are important reasons for delaying implementation of the new ICD-10 coding system. Chute CG, Huff SM, Ferguson JA, Walker JM, Halamka JD. Health Aff (Millwood). 2012 Apr;31(4):836-42. Epub 2012 Mar 21 http://www.ncbi.nlm.nih.gov/pubmed/22442180  (Abstract free; Subscription or payment required for full text)

%d bloggers like this: