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). These include:
• factors affecting access and care for persons with CFS; • the science and definition of CFS; and • broader public health, clinical, research and educational issues related to CFS.
Administrative and management support for CFSAC activities is provided by the Office of the Assistant Secretary for Health (OASH). However, staffing will continue to be provided primarily from the Office on Women’s Health, which is part of OASH.
Dr. Nancy C. Lee, Deputy Assistant Secretary for Health – Women’s Health, is the Designated Federal Officer for CFSAC.
Chronic Fatigue Syndrome Advisory Committee (CFSAC) Spring Meeting
The Chronic Fatigue Syndrome Advisory Committee (CFSAC), 2012 spring meeting will be held on Wednesday, June 13, 2012 from 9:00 a.m. until 5:00 p.m. EST and Thursday, June 14, 2012 from 9:00 a.m. until 5:00 p.m. EST.
The meeting will be held at the U.S. Department of Health and Human Services, Hubert Humphrey Building, 200 Independence Avenue, S.W., Room 800, Washington, D.C. 20201. For directions please visit http://www.hhs.gov/about/hhhmap.html .
The meeting will be webcast live and available by audio (listening-only). Additional information and the CFSAC agenda will be posted to the CFSAC website by June 4, 2012.
Update: May 24, 2012
Above notice now reads:
The meeting will provide a live video stream and be available by audio (listening only). Additional information and the CFSAC agenda will be posted to the CFSAC website by June 4, 2012. Instructions for public testimony will be provided at a later date in a Federal Register Notice. We are not accepting requests or testimony at this time.
International Classification of Diseases – Clinical Modification (ICD-CM): Presentation by Donna Pickett, RHIA, MPH, National Center for Health Statistics (NCHS)
On April 9, the US Department of Health and Human Services issued a proposed rule calling for a one year delay in the ICD-10-CM/PCS compliance deadline.
The proposed rule would postpone the compliance date by which providers and industry have to adopt ICD-10-CM by one year, from October 1, 2013 to October 1, 2014.
The proposed rule was published in the Federal Register on April 17, followed by a 30 day period during which CMS will take comments.
Comments should be submitted to HHS no later than 5:00 pm ET on May 17, 2012.
Proposed Rule
The Proposed Rule documentation can be found on this page in PDF and HTML formats:
Administrative Simplification: Adoption of a Standard for a Unique Health Plan Identifier; Addition to the National Provider Identifier Requirements; and a Change to the Compliance Date for ICD-10-CM and ICD-10-PCS Medical Data Code Sets
This proposed rule would implement section 1104 of the Patient Protection and Affordable Care Act (hereinafter referred to as the Affordable Care Act) by establishing new requirements for administrative transactions that would improve the utility of the existing Health Insurance Portability and Accountability Act of 1996 (HIPAA) transactions and reduce administrative burden and costs. It proposes the adoption of the standard for a national unique health plan identifier (HPID) and requirements or provisions for the implementation of the HPID. This rule also proposes the adoption of a data element that will serve as an other entity identifier (OEID), an identifier for entities that are not health plans, health care providers, or “individuals,” that need to be identified in standard transactions. This proposed rule would also specify the circumstances under which an organization covered health care provider must require certain noncovered individual health care providers who are prescribers to obtain and disclose an NPI. Finally, this rule proposes to change the compliance date for the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for diagnosis coding, including the Official ICD-10-CM Guidelines for Coding and Reporting, and the International Classification of Diseases, 10th Revision, Procedure Coding System (ICD-10-PCS) for inpatient hospital procedure coding, including the Official ICD-10-PCS Guidelines for Coding and Reporting, from October 1, 2013 to October 1, 2014.
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:
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…
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 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…
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:
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.
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…
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.
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
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…
This material relates to the forthcoming US specific “clinical modification” of the WHO ICD-10, known as “ICD-10-CM.” It does not relate to other country specific clinical modifications of ICD-10.
Update @ February 27:There has been considerable coverage of HHS’s announcement to delay the compliance date for ICD-10-CM.
Industry experts respond as HHS has confirmed its intent to delay the ICD-10 compliance deadline, according to its latest press release. HCPro contacted numerous industry experts for their thoughts on the recent announcement by CMS. Although reactions are mixed, experts agree that forward progress on ICD-10 readiness for providers is essential…
One school of thought is that it will be delayed for a year or two; but CMS’ announcement mentioned that only “certain healthcare entities” would be granted a reprieve. Which entities? We don’t know yet.
On January 16, 2009, Department of Health and Human Services (HHS) published a Final Rule in the Federal Register mandating adoption of ICD-10-CM and ICD-10-PCS to replace ICD-9-CM in HIPAA transactions, with a compliance date of October 1, 2013.
Until implementation, codes in ICD-10-CM are not valid for any purpose or use. ICD-10-CM has been subject to partial code freeze since October 1, 2011.
The 2012 release of ICD-10-CM is now available from the CDC site and replaces the December 2011 release:
On February 16, HHS Secretary Kathleen Sebelius issued a press release announcing that HHS will initiate a process to postpone the date by which certain health care entities are required to comply with International Classification of Diseases, 10th Edition diagnosis and procedure codes.
HHS Secretary Kathleen Sebelius said, “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.”
HHS has yet to announce a new compliance date but it is speculated that the delay would be for at least one year, rather than for a few months.
The train’s already left the station for organizations that have been prepping for an October 2013 ICD-10 deadline, say health IT organizations and CIOs.
Yesterday, American Health Information Management Association (AHIMA) issued a statement and press release in response to HHS Sebelius’ February 16 announcement to delay the ICD-10-CM compliance date.
AHIMA represents more than 64,000 Health Information Management professionals in the United States and around the world. www.ahima.org
Feb 22, 2012 01:12 pm | posted by Kevin Heubusch | ICD-10
This week AHIMA announced it will reach out to leaders at the Department of Health and Human Services and urge there be no delay in the implementation of ICD-10-CM and ICD-10-PCS.
“We recommend that HHS reach out to the full healthcare community and gather more information about the great strides many have achieved— in good faith—since the ICD-10 deadline was set in January 2009,” said AHIMA CEO Lynne Thomas Gordon, quoted in a statement.
Further, AHIMA encouraged the healthcare community to continue its implementation planning and not let up its efforts.
In a statement released today, AHIMA offered 10 reasons not to delay ICD-10 implementation.
Ten Reasons We Need ICD-10 Now
It Enhances Quality Measures. Without ICD-10 data, serious gaps will remain in the healthcare community’s ability to extract important patient health information needed for physicians and others to measure quality care.
Research Capabilities Will Improve Patient Care. Data could be used in a more meaningful way to enable better understanding of complications, better design of clinically robust algorithms, and better tracking of the outcomes of care. Greater detail offers the ability to discover previously-unrecognized relationships or uncover phenomenon such as incipient epidemics early.
Significant Progress Has Already Been Made. For several years, hospitals and healthcare systems, health plans, vendors and academic institutions have been preparing in good faith to put systems in place to transition to ICD-10. A delay would cause an unnecessary setback.
Education Programs Are Underway. To ready the next generation of HIM professionals, academic institutions have set their curriculum for two-year, four-year, and graduate programs to include ICD-10.
Other Healthcare Initiatives Need ICD-10. ICD-10 is the foundation needed to support other national healthcare initiatives such as meaningful use, value-based purchasing, payment reform, quality reporting and accountable care organizations. Electronic health record systems being adopted today are ICD-10 compatible. Without ICD-10, the value of these other efforts is greatly diminished.
It Reduces Fraud. With ICD-10, the detail of health procedures will be easier to track, reducing opportunities for unscrupulous practitioners to cheat the system.
It Promotes Cost Effectiveness. More accurate information will reduce waste, lead to more accurate reimbursement and help ensure that healthcare dollars are used efficiently.
If ICD-10 Is Delayed:
Resources Will Be Lost. For the last three years, the healthcare community has invested millions of dollars analyzing their systems, aligning resources and training staff for the ICD-10 transition.
Costs Will Increase. A delay will cause increased implementation costs, as many healthcare providers and health plans will need to maintain two systems (ICD-9 and ICD-10). Delaying ICD-10 increases the cost of keeping personnel trained and prepared for the transition. Other systems, business processes, and operational elements also will need upgrading. More resources will be needed to repeat some implementation activities if ICD-10 is delayed.
Jobs Will Be Lost.To prepare for the transition, many hospitals and healthcare providers have hired additional staff whose jobs will be affected if ICD-10 is delayed.
And Finally…
We Can’t Wait for ICD-11. The foundations of ICD-11 rest on ICD-10 and the foundation must be laid before a solid structure can be built. ICD-11 will require the development and integration of a new clinical modification system. Even under ideal circumstances, ICD-11 is still several years away from being ready for implementation in the United States.*
In the report by Tom Sullivan (Health Care Finance News, February 16, 2012), Christopher Chute, MD, who chairs the ICD-11 Revision Steering Group, warned of a possible further delay for completion of ICD-11, from 2015 to 2016.
Implementation of ICD-11 has already been shifted from 2012 to 2014, then last year, to 2015+. These are projections for pilot, then global implementation for ICD-11.
The DHHS Office of the Secretary Final Rule document, February 2009, stated:
“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.”
Canada uses a clinical modification of ICD-10 called ICD-10-CA. WHO-FIC meeting materials suggest that Canada might not move onto ICD-11 (or a modification of ICD-11) until 2018+. Australia, which uses a clinical modification of ICD-10 called ICD-10-AM, is discussing potentially earlier adoption of ICD-11.
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). These include:
• factors affecting access and care for persons with CFS; • the science and definition of CFS; and • broader public health, clinical, research and educational issues related to CFS.
Administrative and management support for CFSAC activities is provided by the Office of the Assistant Secretary for Health (OASH). However, staffing will continue to be provided primarily from the Office on Women’s Health, which is part of OASH.
Dr. Nancy C. Lee, Deputy Assistant Secretary for Health – Women’s Health, is the Designated Federal Officer for CFSAC.
The Agenda item with the most relevance for this site was the issue of the current proposals for chapter placement and coding for Chronic fatigue syndrome in the forthcoming US specific ICD-10-CM, the proposals presented for consideration at the September meeting of the ICD-9-CM Coordination and Maintenance Committee on behalf of the Coalition for ME/CFS, and an alternative proposal presented by NCHS.
See this Dx Revision Watch post (Post #118, December 27, 2011) for a report on the Fall 2012 Meeting presentation by Donna Pickett (NCHS) and discussions of proposals for ICD-10-CM:
International Classification of Diseases – Clinical Modification (ICD-CM): Presentation by Donna Pickett, RHIA, MPH, National Center for Health Statistics (NCHS)
Recommendations out of the Fall 2011 CFSAC Meeting
The specific recommendations articulated by the Committee are:
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.
2. CFSAC recommends to the Secretary that the NIH or other appropriate agency issue a Request for Applications (RFA) for clinical trials research on chronic fatigue syndrome/myalgic encephalomyelitis (CFS/ME).
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.
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 CFS as a psychiatric condition in the U.S. disease classification systems.
b) CFSAC rejects the current classification of 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 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 CFSAC’s recommendations of August 2005 and May 2011. CFSAC rejects CDC’s National Center for Health Statistics Option 2 and recommends that 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” [sic *] 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.
This final recommendation was also provided to the National Center for Statistics at the CDC prior to the November 18, 2011 deadline for comments along with the following rationale:
We feel that the interests of patients, the scientific and medical communities, continuity and logic are best served by keeping CFS, (B)ME (Benign Myalgic Encephalomyelitis) and PVFS (Post Viral Fatigue Syndrome) in the same broad grouping category. Current scientific evidence would indicate there are more similarities between the three entities than there are differences. Whether they are synonyms for the same underlying concept, disease entities and sub‐entities, or merely the best coding guess is unclear. In reality, any or all of the above may be correct. While the relationship between CFS, B(ME) and PVFS is not stated, that they are grouped together in ICD 10 (WHO) would indicate some rationale for a connection. Our understanding is that this association will be maintained in the ICD 11, which may also include further description of the relationship. Exclusions specific to chronic fatigue (a symptom present in many illnesses) and neurasthenia (not a current diagnosis) also seem to be under consideration for ICD 11.
*Ed: Should be “Excludes1″. For definitions for “Excludes1″ and “Excludes2″ see Post #118
The Minute for Ms Pickett’s presentation “International Classification of Diseases—Clinical Modification (ICD‐CM) Donna Pickett, National Center for Health Statistics (NCHS/Centers for Disease Control and Prevention)” and Committee discussions in response to that presentation can be found on Pages 4-10 of the PDF for Minutes Day One (November 8, 2011).
Video of presentation in Post #118. Ms Pickett’s presentation slides here in PDF format.
The Minute for the proposal and unanimous approval of a revised and expanded Recommendation to HHS on the coding of CFS in ICD-10-CM can be found on Pages 43-44 of the PDF for Minutes Day Two (November 9, 2011). Video in Post #118.
As reported in Post #118, following the September 14 meeting of the ICD-9-CM Coordination and Maintenance Committee, NCHS had invited comments from stakeholders on the proposals in Option 1 (presented by the Coalition for ME/CFS) and Option 2 (alternative proposals by NCHS).
The closing date for comments was November 18, 2011.
A decision was expected before the end of December but since any decision that might have been reached on these proposals has yet to be announced, I have raised some queries with Ms Pickett around the decision making process (see Post #118). I will update when a response has been received from Ms Pickett’s office or a public announcement made.
International Classification of Diseases – Clinical Modification (ICD-CM): Presentation by Donna Pickett, RHIA, MPH, National Center for Health Statistics (NCHS), November 27, 2011
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)
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
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:
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]
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.
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:
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)”.
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:
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.
[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.]
CFSAC Fall 2011 Meeting (November 8-9) Audio Call-In Information
The Meeting of the Chronic Fatigue Advisory Committee will be available via AUDIO Lines. The following call-in information will provide access to the meeting via audio lines:
Please use the following passcodes for each day:
Passcodes:
Tuesday, November 8: 24756185
Wednesday, November 9: 24759937
Please note, each caller can press *0 at any time during the call tocontact the operator for support.
There will be an operator on the line to welcome you and each caller will be asked their name and email address (this is not a requirement). You will be placed into the conference.
During the lunch hour, callers may hold the line or choose to call back to access the conference.
The CFSAC meeting will begin from 9:00 am – 5:30 pm Tuesday, November 8 and 9:00 am – 4:30 pm on Wednesday, November 9.
On July 15, the Coalition 4 ME/CFS submitted a written proposal to the ICD-9-CM Coordination and Maintenance Committee to restore CFS to Chapter 6 “Diseases of the Nervous System” code G93.3 in the ICD-10 Clinical Modification (ICD-10-CM) in the US.
This action follows the September 2004, August 2005 and May 2011 recommendations of the federally-appointed Chronic Fatigue Syndrome Advisory Committee (CFSAC). In each case, the committee recommended that CFS be in the neurological classification in the ICD-10-CM, in line with the rest of the world.
On September 14, the Coalition 4 ME/CFS made an oral presentation to the committee and responded to concerns expressed by audience members.
The coalition has written a letter to clinicians, researchers and other medical professionals outlining the National Center for Health Statistics (NCHS) and the coalition option for modification
We have also included a sample letter for medical professionals and the public to give input rejecting NCHS’s option #2 in favor of the coalition’s proposal option
We are asking medical professionals to comment on this important issue before the comment period ends on November 18.
Medical professionals wanting to add their signature to the coalition’s prepared letter to NCHS that will be submitted prior to the November 18 deadline can contact Mike Munoz at info@coalition4MECFS.org
More information concerning the coalition and the ICD initiative can be found at
Comments on proposals need to be submitted by November 18.
Comments from stakeholders, preferably via email, should be submitted to:
Donna Pickett RHIA, MPH
Medical Classification Administrator
National Center for Health Statistics – CDC
3311Toledo Road Hyattsville, MD 20782
Via email: nchsicd9CM@cdc.gov
You can download an Audio of the September 14 NCHS meeting here:
[Note this is 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.]
The information in this report refers only to the existing international WHO ICD-10 and not to the forthcoming ICD-11 or to any country specific, clinical modification of ICD-10.
New: Online ICD-10 Version for 2010
I reported some months ago that according to documentation from WHO-FIC meeting materials, it was understood that a version of ICD-10 for 2010 was planned to be published online by WHO, Geneva, earlier this year.
This would replace the ICD-10 online version for 2007 and incorporate all the annual updates to ICD-10 from 2007 to 2010.
This is now up online.
A searchable version of ICD-10 for 2010 is available at this URL:
International Statistical Classification of Diseases and Related Health Problems 10th Revision
It is presented on a platform similar to the platform being used for the ICD-11 Alpha Draft, that is, a list of ICD-10 Chapters on the left side of the screen, arranged with hierarchical parent > child categories, with the category codings set out on the right side of the screen.
This is the URL for ICD Title term G93.3 Postviral fatigue syndrome:
If “Chronic fatigue syndrome” is entered into the Search box, a drop down reads:
“Syndrome – fatigue – chronic – G93.3″
(Which is the way it is set out in Volume 3 The Alphabetical Index.)
Mouse hover over the orange square on the left of the dark blue drop down and the “Alt text” reads:
“Found in Index”
There is a User Guide for ICD-10 Version: 2010 but the platform is not difficult to navigate, just select a chapter and click on the little grey arrows to display parent class and Title term categories and their child categories – you can’t break anything:
Those of us with websites that have URLs pointing to specific ICD-10 version for 2007 categories will need to adjust URLs for the new platform, as code specific URLs are pointing only to the ICD-10 Version: 2010 opening page, for example:
what displayed in ICD-10 version for 2007 at this path:
There has of late been speculation that it would be bad for U.S. patients if CFS and M.E. were placed in the same category in the neurology chapter of ICD-10-CM, the “clinical manual” of ICD-10 that will be adopted for use in the United States.
But the fact of the matter is that in ICD-10, CFS already IS coded to G93.3, “PVFS and M.E.” in the index, which is as authoritative as the tabular version. [PVFS stands for Post-Viral Fatigue Syndrome, and is not diagnosed very frequently any more - not at all in the U.S.]. It already IS coded in neurology.
110 nations use ICD-10 as-is, including the UK. Australia has a clinical version that does not alter the codes for M.E. or CFS. But Canada and Germany have clinical versions that place CFS in the tabular version of ICD-10, in G93.3 with M.E. In fact, it was the Canadian clinical version, ICD-10-CA, which led to the highly regarded Canadian Consensus Criteria for ME/CFS in 2003.
NOBODY EXCEPT THE UNITED STATES CODES CFS IN THE “R” CHAPTER. If we coded CFS at R53.82, which was the plan of NCHS, we would have been the ONLY nation in the world to do so.
Furthermore, M.E. is not a known diagnosis in the U.S. (WE know about it, but very few doctors do.) There is no definition for it approved by CDC. We can now point to the new definition that was published in the Journal of Internal Medicine, but that is more likely to enable researchers in the US and Canada to use M.E. if they want to, than to trickle down to U.S. clinicians [1]. Part of the problem is that when M.E. replaced atypical polio as a disease name in British commonwealth nations and Europe, in the U.S. the new name was epidemic neuromyesthenia, which has not (to my knowledge) been diagnosed in decades.
So if CFS gets coded as R53.82 in the U.S.’s ICD-10-CM, yes, M.E. will be less likely to confuse with CFS – but that would only be in the U.S., and in the U.S. we only get diagnosed with that revolting name CFS anyway. At least we could get them scratching their heads and asking, “What is M.E.?” if both diseases were placed together where those of you outside the U.S. already have it.
Given that U.S. doctors do not have a high opinion of CFS, keeping it under “R” in “vague signs and symptoms” would only reinforce their prejudice against it as a “garbage diagnosis” – something you diagnose when you run out of ideas.
Finally, there was an inadvertent error in an earlier Co-Cure message about getting CFS out of the “R” category. The “R” category is not for psychiatric diagnoses.
British psychiatrists use “fatigue syndrome,” which is coded at F48.0 under neuroses at “neurasthenia.”. Then when they write about it, they mix and match terms so it looks as if CFS is the same thing, and therefore it goes in F48.0. That is a serious problem in the UK. [I have to admit to being alarmed recently when a U.S. virologist connected CFS not to the history of atypical polio, which is pretty well established, but to the arcane nineteenth century diagnosis of neurasthenia. Please don't do that!]
We are not (I hope) in current danger of being coded under neuroses at F48.0, neurasthenia, in the U.S. But the “R” diagnosis is sufficiently vague that it wouldn’t be difficult to use it to claim CFS patients really have CSSD (Complex Somatic Symptom Disorder), the category British psychiatrist and CBT advocate Michael Sharpe is trying to shoehorn into DSM-5, the new version of the American Psychiatric Association’s huge diagnostic tome. So it does leave us vulnerable [2].
To those outside the U.S. I would say, look to ICD-11. That’s what will affect you the most. To those in the U.S. (where we are finally getting around to adopting ICD-10-CM two decades after ICD-10 was written), what WE need is simply to get in step with the rest of the world now.
Mary M. Schweitzer PhD
Related material
[1] New International Consensus Criteria for M.E., Journal of Internal Medicine
Volume 270, Issue 4, pages 327–338, October 2011
Carruthers, B. M., van de Sande, M. I., De Meirleir, K. L., Klimas, N. G., Broderick, G., Mitchell, T., Staines, D., Powles, A. C. P., Speight, N., Vallings, R., Bateman, L., Baumgarten-Austrheim, B., Bell, D. S., Carlo-Stella, N., Chia, J., Darragh, A., Jo, D., Lewis, D., Light, A. R., Marshall-Gradisbik, S., Mena, I., Mikovits, J. A., Miwa, K., Murovska, M., Pall, M. L. and Stevens, S. (2011), Myalgic encephalomyelitis: International Consensus Criteria. Journal of Internal Medicine, 270: 327–338. doi: 10.1111/j.1365-2796.2011.02428.x
Reminder: Comment period on ICD-10-CM proposed delay ends May 17
April 25, 2012 — meagendaReminder: Comment period on ICD-10-CM proposed delay ends May 17
Post #159 Shortlink: http://wp.me/pKrrB-23H
On April 9, the US Department of Health and Human Services issued a proposed rule calling for a one year delay in the ICD-10-CM/PCS compliance deadline.
The proposed rule would postpone the compliance date by which providers and industry have to adopt ICD-10-CM by one year, from October 1, 2013 to October 1, 2014.
The proposed rule was published in the Federal Register on April 17, followed by a 30 day period during which CMS will take comments.
Comments should be submitted to HHS no later than 5:00 pm ET on May 17, 2012.
Proposed Rule
More information on the proposed rule is available from this CMS fact sheet
HHS PROPOSES ONE-YEAR DELAY OF ICD-10 COMPLIANCE DATE (CMS-0040-P)
Submitting comment
Submitting comment by post:
Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS–0040–P
P.O. Box 8013
Baltimore, MD 21244–8013
Submitting comment online:
Go to the Federal Regulations website, here:
http://www.regulations.gov/#!documentDetail;D=CMS-2012-0043-0001
Hit the Submit a Comment button, top right of web page
http://www.regulations.gov/#!submitComment;D=CMS-2012-0043-0001
For delivery by hand see the Alternate Ways to Comment pop up, top right of Submit a Comment page.
Related material
Press release: April 9, 2012
Summary Proposal Rule
This proposed rule would implement section 1104 of the Patient Protection and Affordable Care Act (hereinafter referred to as the Affordable Care Act) by establishing new requirements for administrative transactions that would improve the utility of the existing Health Insurance Portability and Accountability Act of 1996 (HIPAA) transactions and reduce administrative burden and costs. It proposes the adoption of the standard for a national unique health plan identifier (HPID) and requirements or provisions for the implementation of the HPID. This rule also proposes the adoption of a data element that will serve as an other entity identifier (OEID), an identifier for entities that are not health plans, health care providers, or “individuals,” that need to be identified in standard transactions. This proposed rule would also specify the circumstances under which an organization covered health care provider must require certain noncovered individual health care providers who are prescribers to obtain and disclose an NPI. Finally, this rule proposes to change the compliance date for the International Classification of Diseases, 10th Revision, Clinical Modification (ICD-10-CM) for diagnosis coding, including the Official ICD-10-CM Guidelines for Coding and Reporting, and the International Classification of Diseases, 10th Revision, Procedure Coding System (ICD-10-PCS) for inpatient hospital procedure coding, including the Official ICD-10-PCS Guidelines for Coding and Reporting, from October 1, 2013 to October 1, 2014.