Reminder: Comment period on ICD-10-CM proposed delay ends May 17

Reminder: 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

The Proposed Rule documentation can be found on this page in PDF and HTML formats:

http://www.regulations.gov/#!documentDetail;D=CMS-2012-0043-0001

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

Document ID: CMS-2012-0043-0001 Document Type: Proposed Rule
Docket ID: CMS-2012-0043 RIN:

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. 

What’s new in the ICD-11 Alpha drafting platform? (CFS, PVFS, ME)

What’s new in the ICD-11 Alpha drafting platform? (CFS, PVFS, ME)

Post #157 Shortlink: http://wp.me/pKrrB-22h

 

Screenshot: ICD-11 Alpha Browser Foundation view selected, logged in at April 10, 2012:

Chapter 6: Diseases of the nervous system

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

Apr 09 – 11:02 UTC

 

ICD-11 Beta drafting platform to launch in May?

As reported in previous posts, according to the timeline, the ICD-11 Beta drafting platform is supposed to be launching this May.

ICD-11 Revision Steering Group has yet to announce whether the Beta platform remains on target for a May release and if so, on what date it will be launched – so I cannot give you a date yet.

Like the Alpha Drafting Browser, the Beta drafting platform will be a work in progress – not a final Beta draft. The final Beta isn’t scheduled until 2014, after the ICD-11 field trials have been undertaken.

When it does launch, the Beta platform is intended to be accessible to professionals and the public for viewing.

Registered or logged in users will have greater access to content and will be able to interact with the platform to read comments, comment on proposals and make suggestions, as part of the ongoing drafting process.  

In the meantime, the publicly viewable version of the Alpha drafting platform (known as the ICD-11 Alpha Browser) can still be accessed here:

http://apps.who.int/classifications/icd11/browse/f/en

The various ICD-11 Revision Topic Advisory Groups are carrying out their draft preparation work on a separate, more complex multi-author drafting platform that is accessible only to WHO and ICD Revision personnel.

 

Alpha drafting platform

As before, the publicly viewable version of the Alpha Browser should be viewed with the following caveats in mind:

the Alpha draft is a work in progress; it is incomplete; it may contain errors and omissions; it is in a state of flux and updated daily; textual content, codes and “Sorting labels” are subject to change as chapters are reorganized and content populated; the content has not been approved by Topic Advisory Groups, Revision Steering Group or WHO.

It is possible to register, or sign into the platform using existing accounts with several third party account providers such as Google, Yahoo and myOpenID, for increased access and functionality. Once signed in, Comments and Questions can be read and PDFs of the drafts of the top level linearizations can be downloaded from the Linearization tab.

See the Alpha Browser User Guide for information on how the Alpha Browser functions:

http://apps.who.int/classifications/icd11/browse/Help/en

 

The ICD-11 “Content Model”

ICD-11 will be available in both print and online versions and unlike most chapters of ICD-10, will include descriptive content for ICD terms.

For the online version of ICD-11, all ICD entities will include a definition and a number of additional key descriptive fields – between 7 and 13 pre-defined parameters, populated according to a common “Content Model” (Content Model Reference Guide January 2011).

For example, ICD entity Title, Definition, Synonyms, Narrower Terms, Exclusions, Body Site, Body System, Signs and Symptoms, Causal Mechanisms, and possibly Diagnostic Criteria for some entities.*

*According to the iCAT User Google Group message board, these fields may have been revised since the January 2011 Content Model Reference Guide was published; Content Model parameters in the Beta draft may therefore differ from those currently displaying in the public Alpha drafting platform.

The print version will use a concise version of Definition due to space constraints.

In the Alpha Browser, not all these Content Model parameters display in the Foundation and Linearization views and not all of the parameters that have been listed for individual entities have had their draft text added yet, as some chapters are more advanced for the population of proposed content than others.

So the Alpha draft is still very patchy and many entities have no Definition and little or no other proposed content filled in.

With no “Category Discussion Notes” or “Change history” pop-up windows visible in the public version of the Alpha, the viewer cannot determine the rationales behind the reorganization of terms and hierarchies within the various chapters.

 

Chapter location and hierarchy for CFS, PVFS and (Benign) ME in ICD-11

I have been reporting since June 2010 that the proposals for ICD-11 Alpha Draft, as far as one could determine, appeared to be:

1] That a change of hierarchy had been recorded in a “Category Discussion Note”, dated May 1, 2010, between ICD-10 Title term “Postviral fatigue syndrome” and “Chronic fatigue syndrome”. (“Category Discussion Notes” and “Change History” pop-ups did display in the earlier iCAT version of the Alpha drafting platform.)

You can view a screenshot from June 2010 of that “Change history” record here:

http://dxrevisionwatch.files.wordpress.com/2010/06/change-history-gj92-cfs.png

The Definition field on the “Chronic fatigue syndrome” description panel in the current Alpha Browser is currently blank but in June 2010, the Definition had stood as in this contemporaneous screenshot:

http://dxrevisionwatch.files.wordpress.com/2010/05/2icatgj92cfsdef.png

2] That “Chronic fatigue syndrome” had been designated as an ICD-11 Title term within ICD-11 Chapter 6: Diseases of the nervous system, with the capacity for a Definition and up to 10 additional descriptive parameters.

3] That “Benign myalgic encephalomyelitis” had been specified as an Inclusion term to ICD-11 Title term “Chronic fatigue syndrome” but that the relationships between the three terms, PVFS, (B) ME and CFS had yet to be specified, as in this screenshot from June 2010:

http://dxrevisionwatch.files.wordpress.com/2010/05/2icatgj92cfsterms.png

 

What is currently showing in the Chapter 6 Foundation Component?

It isn’t possible to bring up a discrete ICD Title listing for either “Benign myalgic encephalomyelitis” or “Postviral fatigue syndrome” in either the Foundation Component or the Linearization.

In the Foundation view only, for Chapter 6: Diseases of the nervous system, “Chronic fatigue syndrome” is listed as a Title term with the ICD-10 legacy ID “ID:http://who.int/icd#G93.3″;

the Definition field is currently blank;

a list of terms has recently been added under “Synonyms”;

one term has recently been added under “Narrower Terms”.

(Note: there is a small asterisk at the end of term “Benign myalgic encephalomyelitis” which is listed at the top of the “Synonyms” list. The asterisk “Hover text” reads “This term is an inclusion term in the linearizations.”)

If you want to view the listing directly on the Browser site (note the “Comment” and “Questions” icons which open up pop-up windows next to terms for reading/commenting won’t display unless you have already registered and logged in) go here:

ICD-11 Alpha Browser Foundation view:

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

ID:http://who.int/icd#G93.3

Chronic fatigue syndrome

Parent(s)

Selected cause is Remainder of diseases of the nervous system in Condensed and selected Infant and child mortality lists
Selected Cause is All other diseases in the Selected General mortality list
Selected cause is Diseases of the nervous system

Definition

This entity does not have a definition at the moment.

Synonyms

Benign myalgic encephalomyelitis *  [Ed: Hover text over asterisk reads: "This term is an inclusion term in the linearizations."]
akureyri
akureyri disease
cfs – chronic fatigue syndrome
chronic fatigue syndrome nos   [Ed: from current proposals for ICD-10-CM, Chapter 18, R53.82]
chronic fatigue, unspecified   [Ed: from current proposals for ICD-10-CM, Chapter 18, R53.82]
epidemic neuromyasthenia
iceland disease
icelandic disease
me – myalgic encephalomyelitis
myalgic encephalomyelitis
myalgic encephalomyelitis syndrome
postviral fatigue syndrome
pvfs – postviral fatigue syndrome

Narrower Terms

neuromyasthenia

Body Site

Entire brain (body structure)
Brain structure (body structure)

Causal Mechanisms

Virus (organism)

 

What’s new in Chapter 5: Mental and behavioural disorders?

As reported in Dx Revision Watch post: http://wp.me/pKrrB-1Vx,  the category “Somatoform Disorders” in Chapter 5, Mental and behavioural disorders is currently renamed to “BODILY DISTRESS DISORDERS”, under which currently sit three new child categories:

5M0 Mild bodily distress disorder
5M1 Moderate bodily distress disorder
5M2 Severe bodily distress disorder.

Chapter 5 Linearization view:

http://apps.who.int/classifications/icd11/browse/l-m/en#/http%3a%2f%2fwho.int%2ficd%23F45

Chapter 5 Foundation view:

http://apps.who.int/classifications/icd11/browse/f/en#/http%3a%2f%2fwho.int%2ficd%23F45

(Click on the little grey arrows to display the child categories):

Child categories to parent ”BODILY DISTRESS DISORDERS”:

http://apps.who.int/classifications/icd11/browse/f/en#/http%3a%2f%2fwho.int%2ficd%231905_dd0250d2_e8cd_4c48_a93f_7997cc1c8b07

BODILY DISTRESS DISORDERS

5M0 Mild bodily distress disorder
5M1 Moderate bodily distress disorder
5M2 Severe bodily distress disorder
5M3 Somatization disorder
5M4 Undifferentiated somatoform disorder
5M5 Somatoform autonomic dysfunction
5M6 Persistent somatoform pain disorder
      > 5M6.0 Persistent somatoform pain disorder
      > 5M6.1 Chronic pain disorder with somatic and psycological [sic] factors
5M7 Other somatoform disorders
5M8 Somatoform disorder, unspecified

None of these three new (proposed) categories have had any Definitions or other textual content added to the description panels on the right hand side of the Alpha Browser page since I first reported this change in February.

It is still not possible to determine what disorders ICD-11 intends might be captured by these three new (proposed) terms, should ICD-11 Revision Steering Group and WHO classification experts consider these terms to be valid constructs and approve their progression through to the Beta draft.

Because no “Change Notes” or “Change history” pop-up windows display in this version of the Alpha Drafting browser, it is not possible to determine:

whether ICD-11 is proposing to introduce three new terms – 5M0 Mild bodily distress disorder; 5M1 Moderate bodily distress disorder; 5M2 Severe bodily distress disorder, in addition to retaining existing ICD-10 terms, 5M3 thru 5M8;

how ICD Revision intends to define these (proposed) new terms at 5M0, 5M1, 5M2;

how these three (proposed) new terms would relate to the existing ICD-10 “Somatoform Disorders” categories which remain listed as child categories to “BODILY DISTRESS DISORDERS” (apart from “Hypochondriacal disorder” [ICD-10: F45.2], which is now listed as “5H0.5 Illness Anxiety Disorder” in the ICD-11 Alpha Draft).

(See Page 1 and 2 of my report: “Bodily Distress Disorders” to replace “Somatoform Disorders” for ICD-11?: http://wp.me/pKrrB-1Vx  )

 

References:

ICD-11 Revision: http://www.who.int/classifications/icd/revision/en/

ICD-11 Alpha Browser User Guide: http://www.who.int/classifications/icd/revision/caveat/en/index.html
Alpha Browser Foundation view: http://apps.who.int/classifications/icd11/browse/f/en#
Alpha Browser Linearization view: http://apps.who.int/classifications/icd11/browse/l-m/en#
“Bodily Distress Disorders” to replace “Somatoform Disorders” for ICD-11?: http://wp.me/pKrrB-1Vx

HHS proposes one year delay for ICD-10-CM compliance

HHS proposes one year delay for ICD-10-CM compliance

Post #156 Shortlink: http://wp.me/pKrrB-22q

Yesterday, 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.

According to a Centers for Medicare and Medicaid Services (CMS) press release, 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. 

Official publication of the proposed rule is expected to be published in the Federal Register on April 17, followed by a 30 day period during which CMS will take comments.

Full proposal document (pre-publication PDF version)

      http://www.ofr.gov/OFRUpload/OFRData/2012-08718_PI.pdf

or at:

https://s3.amazonaws.com/public-inspection.federalregister.gov/2012-08718.pdf

This document is scheduled to be published in the
Federal Register on 04/17/2012 and available online at
http://federalregister.gov/a/2012-08718 , and on FDsys.gov

Press release issued April 9, 2012:

http://www.hhs.gov/news/press/2012pres/04/20120409a.html

Details for: NEW HEALTH CARE LAW PROVISIONS CUT RED TAPE, SAVE UP TO $4.6 BILLION

For Immediate Release: Monday, April 09, 2012
Contact: CMS Office of Public Affairs
202-690-6145

NEW HEALTH CARE LAW PROVISIONS CUT RED TAPE, SAVE UP TO $4.6 BILLION

Department of Health and Human Services (HHS) Secretary Kathleen Sebelius today announced a proposed rule that would establish a unique health plan identifier under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The proposed rule would implement several administrative simplification provisions of the Affordable Care Act.

The proposed changes would save health care providers and health plans up to $4.6 billion over the next ten years, according to estimates released by the HHS today. The estimates were included in a proposed rule that cuts red tape and simplifies administrative processes for doctors, hospitals and health insurance plans.

“The new health care law is cutting red tape, making our health care system more efficient and saving money,” Secretary Sebelius said. “These important simplifications will mean doctors can spend less time filling out forms and more time seeing patients.”

Currently, when health plans and entities like third party administrators bill providers, they are identified using a wide range of different identifiers that do not have a standard length or format. As a result, health care providers run into a number of time-consuming problems, such as misrouting of transactions, rejection of transactions due to insurance identification errors, and difficulty determining patient eligibility.

The rule simplifies the administrative process for providers by proposing that health plans have a unique identifier of a standard length and format to facilitate routine use in computer systems. This will allow provider offices to automate and simplify their processes, particularly when processing bills and other transactions.

The proposed rule also delays required compliance by one year– from Oct. 1, 2013, to Oct. 1, 2014– for new codes used to classify diseases and health problems. These codes, known as the International Classification of Diseases, 10th Edition diagnosis and procedure codes, or ICD-10, will include new procedures and diagnoses and improve the quality of information available for quality improvement and payment purposes.

Many provider groups have expressed serious concerns about their ability to meet the Oct. 1, 2013, compliance date. The proposed change in the compliance date for ICD-10 would give providers and other covered entities more time to prepare and fully test their systems to ensure a smooth and coordinated transition to these new code sets.

The proposed rule announced today is the third in a series of administrative simplification rules in the new health care law. HHS released the first in July of 2011 and the second in January of 2012, and plans to announce more in the coming months.

More information on the proposed rule is available on fact sheets at

http://www.cms.gov/apps/media/fact_sheets.asp

The proposed rule may be viewed at www.ofr.gov/inspection.aspx . Comments are due 30 days after publication in the Federal Register.

Media coverage:

MedPage Today

HHS Announces ICD-10 Delay

Joyce Frieden, News Editor, MedPage Today | April 09, 2012

 

ICD10 Watch

Breaking News: HHS proposes 1-year delay in ICD-10 implementation deadline

Carl Natale | April 09, 2012

 

Healthcare Finance News

HHS proposes one-year ICD-10 delay

Tom Sullivan, Government Health IT | April 10, 2012

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

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

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

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

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

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

HC Pro

New ICD-10 implementation date expected in April

ICD-10 Trainer | March 21, 2012

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

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

HC Pro Just Coding

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

March 20, 2012

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

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

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

Carl Natale | March 30, 2012

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

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

Read full round up by Carl Natale

 

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

Health Affairs

At the Intersection of Health, Health Care, and Policy

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

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

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

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

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

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

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

Author Affiliations

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

Abstract

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

Full free text

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

Why not just skip right to ICD-11?

Tom Sullivan, Government Health IT| March 13, 2012

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

Are we repeating our own faulty history?

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

Read full article by Tom Sullivan

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

3M Health Information

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

Rhonda Butler | March 26, 2012

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

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

What have we been doing for the last 19 years…

Read full article

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

Contains ICD-10-CM timeline

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

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

Psychiatric Times

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

James Phillips, MD | 07 March 2012

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

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

Read full commentary

 

Related posts:

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

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

AHIMA: Ten Reasons to Not Delay ICD-10 (ICD-10-CM)

AHIMA: Ten Reasons to Not Delay ICD-10 (ICD-10-CM)

Post #147 Shortlink: http://wp.me/pKrrB-1Xw

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.

Further coverage:

Press release

HCPro

Industry Experts Respond to Announcement of ICD-10 Deadline Delay

February 27, 2012

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…

ICD-10 may not be postponed for everyone

Ken Kerry | February 20, 2012

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:

International Classification of Diseases, Tenth Revision, Clinical Modification (ICD-10-CM)

 

HHS announces delay for compliance

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.

Related content:

Post #142 | February 16, 2012

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

For background see: 

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

February 16, 2012 | Tom Sullivan, Government Health IT

HIMSS statement, February 17, 2012

HIMSS Calls for Maintaining October 1, 2013 ICD-10 Implementation Deadline for Most Healthcare Entities

Information Week report

ICD-10 Delay Worries Health IT Leaders

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.

Nicole Lewis | InformationWeek |February 22, 2012

Practice Fusion

HHS Asks for a Delay to the Start of ICD-10

Robert Rowley, MD | February 21, 2012

AHIMA issues statement and press release

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

American Health Information Management Association statement and press release

http://journal.ahima.org/2012/02/22/ten-reasons-to-not-delay-icd-10/

     AHIMA statement IDC-10 Delay 02.17.12

Ten Reasons to Not Delay ICD-10

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

1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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:

1. 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.
2. 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.
3. 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.

“Bodily Distress Disorders” to replace “Somatoform Disorders” for ICD-11?

“Bodily Distress Disorders” to replace “Somatoform Disorders” for ICD-11?

Post #145 Shortlink: http://wp.me/pKrrB-1Vx

The information in this report relates only to proposals for the forthcoming ICD-11; it does not relate to ICD-10 or the forthcoming US specific “clinical modification” of ICD-10, ICD-10-CM.

Part One

This report contains an important update on proposals for ICD-11 Chapter 5: Mental and behavioural disorders.

In a February 16 report by Tom Sullivan for Health Care Finance News, Christopher Chute, MD, who chairs the ICD Revision Steering Group, warns of a possible delay for completion of ICD-11 from 2015 to 2016. Nevertheless, the ICD-11 Beta drafting platform remains scheduled to launch in May, this year.

The Beta drafting platform will take the form of a publicly viewable browser similar to the Alpha drafting platform that has been in the public domain since last May.

You can view the Alpha Drafting Browser here:

Foundation Component view:

http://apps.who.int/classifications/icd11/browse/f/en

Morbidity Linearization view:

http://apps.who.int/classifications/icd11/browse/l-m/en

The Morbidity Linearization is the view that includes (what may be temporarily assigned) sorting codes. These codes are likely to change as chapter organization progresses. Click on the small grey arrows next to the chapters and categories to display parent > child > grandchildren hierarchies. Click on individual terms to display descriptive content in the right hand frame of the Alpha Browser.

Textual content for ICD-11 is in the process of being written and population of content for some chapters is more advanced than others. Content for some of these “ICD-11 Content Model parameters” may display: ID legacy code from ICD-10 (where applicable); Definition; Inclusions; Exclusions; Body Site; Causal Mechanism; Signs and Symptoms.

(For ICD-11, entities will be defined through up to 13 “Content Model parameters” across all chapters – considerably more descriptive content than in ICD-10 and a significant workload for the Topic Advisory Group members and managers who are generating the content for ICD-11.)

The Alpha Browser User Guide is here:

http://apps.who.int/classifications/icd11/browse/Help/en

This page of the User Guide sets out differences between Foundation view and Morbidity Linearization view.

The various ICD Revision Topic Advisory Groups (TAGs) are carrying out their work on a separate, more complex, multi-author drafting platform. Editing histories and “Category and Discussion Notes” are recorded so the progress of proposals and reorganization of ICD entities can be tracked, as the draft evolves.

When the Beta drafting platform launches, interested stakeholders will be invited to register for increased access and interaction with the drafting process by submitting comments and suggestions on draft content and proposals.

It is also possible to register for increased access to the Alpha drafting platform and for downloading PDFs of drafts for the “Print Versions for the ICD-11 Alpha Morbidity Linearization” for all 25 chapters of ICD-11. These are obtainable, once registered and logged in, from the Linearization > Print Versions tab.

Caveats

I’m going to reiterate the ICD-11 Alpha Browser Caveats because it’s important to understand that the ICD-11 Alpha draft is a work in progress – not a static document – and is subject to change.

The draft is updated on a (usually) daily basis; when you view the Alpha Browser, you are viewing a “snapshot” of how the publicly viewable draft stood at the end of the previous day; not all chapters are as advanced as others for reorganization or population of content; the draft is incomplete and may contain errors and omissions.

The codes and “sorting labels” assigned to ICD parent classes, child and grandchildren terms are subject to change as reorganization of the chapters progresses. The Alpha draft has not yet been approved by the Topic Advisory Groups, Revision Steering Group or WHO and proposals for, and content in the draft may not progress to the Beta drafting stage – so be mindful of the fact that the draft is in a state of flux.

We may have a clearer idea of what is being proposed once the Beta drafting platform is released, but as it currently stands, the Alpha lacks clarity; not all textual content will have been generated and uploaded for terms imported from ICD-10 and there may be no definitions or other textual content displaying for proposed new terms.

Two chapters that are a focus of this site are Chapter 5: Mental and behavioural disorders and Chapter 6: Disorders of the nervous system (the Neurology chapter). (ICD-11 is dropping the use of Roman numerals.)

I won’t be reporting on specific categories in Chapter 6 in this post but will do a follow up post for Chapter 6 in a few days; again, there is a lack of clarity for Chapter 6 and requests for specific clarifications, last year, from the chair of Topic Advisory Group Neurology and the lead WHO Secretariat for TAG Neurology have met with no response.

Continued on Page 2: Somatoform Disorders in ICD-10; Somatoform Disorders to Bodily Distress Disorders for ICD-11?

Pages: 1 2

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

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

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

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

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

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

Tom Sullivan reports:

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

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

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

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

 

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

February 16, 2012 | Carl Natale, Editor, ICD10Watch

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

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

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

 

CMS Public Affairs Press Release:

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

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

FOR IMMEDIATE RELEASE
February 16, 2012

HHS announces intent to delay ICD-10 compliance date

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

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

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

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

Report:

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

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

February 16, 2012 | Tom Sullivan, Government Health IT

ICD-11 Beta drafting platform for release in May 2012

ICD-11 Beta drafting platform for release in May 2012

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

ICD-11 Beta drafting platform

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

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

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

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

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

View the presentation here:

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

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

for which it states:

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

Slide #7 states:

• 2011  : Alpha version (ICD 11 alpha draft)

– + 1 YR  : Commentaries and consultations

• 2012  : Beta version & Field Trials Version

– + 2 YR Field Trials

• 2014   : Final version for public viewing

– 2015  : WHA Approval

• 2015+  implementation

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

 

The “Content Model”

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

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

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

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

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

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

 

New Beta drafting browser

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

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

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

Stakeholder participation at the Beta stage

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

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

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

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

ICD Revision Process Alpha Evaluation Meeting documents and PowerPoint slide presentations

 

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

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

CFSAC November 8-9, 2011 meeting: Minutes and Recommendations to HHS posted

CFSAC November 8-9, 2011 meeting: Minutes and Recommendations to HHS posted

Shortlink Post #129: http://wp.me/pKrrB-1Fn

The fall meeting of the Chronic Fatigue Syndrome Advisory Committee (CFSAC) took place on November 8-9, 2011.

Minutes and Committee’s Recommendations to HHS have now been posted on the CFSAC website.

Chronic Fatigue Syndrome Advisory Committee (CFSAC) 

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 Meetings page is here

               Minutes Day One CFSAC Fall 2011 meeting

               Minutes Day Two CFSAC Fall 2011 meeting

Presentations, Public Testimony and links for Videos for Day One and Day Two

 

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:

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)

 

Recommendations out of the Fall 2011 CFSAC Meeting

CFSAC Recommendations – November 8-9, 2011

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

               November 2011 Recommendations Letter to the Secretary (PDF 31 KB)

               November 2011 CFSAC Recommendations Chart (PDF 138 KB)

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.

 

Related post

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), November 27, 2011

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

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

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

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

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

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

No live video streaming

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

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

 

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

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

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

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

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

 

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

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

 

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

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

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

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

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

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

 

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

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

a) That any excludes specified are Excludes1 not Excludes2

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

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

 

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

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

 

New CFSAC November 2011 Meeting Recommendation

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

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

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

The CFSAC May 2011 Recommendation:

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

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

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

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

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

The CFSAC November 2011 Recommendation:

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

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

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

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

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

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

 

Watch a video clip for the Recommendation, here:

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

 

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

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

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

 

Request for clarification 

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

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

On the CDC website it states that:

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

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

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

 

Key documents from the November CFSAC meeting

CFSAC Meetings Page

November 8-9, 2011 CFSAC Meeting Agenda

Presentations

Videos of proceedings

Day One: Tuesday, November 8, 2011

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

Day Two: Wednesday, November 9, 2011

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

Presentations

Tuesday, November 8, 2011

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

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

Wednesday, November 9, 2011

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

Public Testimony 

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

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

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

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

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

 

The two proposals

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

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

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

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

 

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

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

Excludes Notes

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

Excludes1

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

Excludes2

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

 

References

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

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

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

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

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

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