We will be holding a webinar and listening session on
September 2 at 10 AM PT / 1 PM ET to discuss the proposal and hear any concerns and answer questions. You can register in advance for this meeting at
this link.
Details
The World Health Organization publishes a standardized system called the International Classification of Diseases (ICD) to track diseases globally. The most recent version is ICD-11 but most countries use ICD-10. Both the ICD-10 and the ICD-11 classify ME and CFS in the neurological chapter under the lead term of “postviral fatigue syndrome.”
The US version of the ICD-10 is the ICD-10-CM and is used to code diseases in medical records. When ICD-10-CM was implemented in 2015, CFS was moved from the neurological chapter to the Signs and Symptoms chapter and given the same code as the symptom of “chronic fatigue, unspecified.” The term ME/CFS was never added so US doctors must choose either CFS or ME. They almost always choose CFS.
As a result, virtually all cases of ME/CFS in medical records have been dumped into the “chronic fatigue, unspecified” bucket. Using the same code for both ME/CFS and the symptom of “chronic fatigue, unspecified” makes it impossible to track the mortality and morbidity of ME/CFS separate from the symptom of nonspecific chronic fatigue. This impacts insurance reimbursement, generation of statistics on disease burden and outcomes, the medical perception of ME/CFS. And it makes it virtually impossible to identify ME/CFS cases in retrospective research using electronic health records, such as that being done for Long COVID.
The submitted proposal recommends the following three changes to ICD-10-CM to address this problem:
- Expand the lead term, “postviral fatigue syndrome,” to “postviral and related fatigue syndromes” to allow for non-viral triggers. ICD rules limit options for the new name as it needs to include the original name
- Add separate subcodes for postviral fatigue syndrome and ME
- Add the terms “myalgic encephalomyelitis/chronic fatigue syndrome” and “ME/CFS” as inclusions of ME
The submitted proposal did not make recommendations regarding the term “chronic fatigue syndrome” because of the lack of consensus on earlier proposals on how this should be addressed.
For more information, see the FAQs at
this link.
https://docs.google.com/document/d/1kyHuHXPZ0nxzF2jIZelyeZqiuq0KWfmm/edit
Proposal to add ME/CFS to the ICD-10-CM August 23, 2021
Frequently Asked Questions
Background:
Seven ME/CFS organizations have submitted a proposal to the National Center for Health Statistics (NCHS) to add myalgic encephalomyelitis/chronic fatigue syndrome (ME/CFS) to the neurological chapter of the International Classification of Diseases (ICD-10-CM).
Today, ME/CFS does not exist in the US ICD-10-CM. Instead, most US doctors assign the code for chronic fatigue syndrome which has the same code as the symptom of chronic fatigue. As a result, it is impossible to accurately track the mortality and morbidity of ME/CFS or its relationship to Long COVID. This affects not only the 836,000 to 2.5 million Americans with ME/CFS but also the tsunami of Long COVID patients who could develop ME/CFS.
The organizations submitting this proposal include the International Association for Chronic Fatigue Syndrome/Myalgic Encephalomyelitis, #MEAction, Open Medicine Foundation, Solve M.E., Massachusetts ME/CFS & FM Association, the Minnesota ME/CFS Alliance, and Pandora Org.
This proposal will be discussed at the upcoming meeting of the NCHS ICD-10-CM Maintenance Committee on September 14-15, 2021. Details on the exact time and date of that meeting will be provided when they are available.
- What is the ICD-10-CM and why is it used?
ICD stands for the International Classification of Diseases and is produced by the World Health Organization. It is used to track the mortality and morbidity of diseases globally. WHO has recently released ICD-11 but most countries are using ICD-10, published in 1990 and will likely do so for a number of years.
Countries are allowed to produce their own clinical modifications as long as they follow WHO standards. The US version of the ICD-10 is the ICD-10-CM, released in 2015. The ICD-10-CM is used in electronic health records to code the diagnoses provided by doctors.
- How is ME/CFS classified in the ICD-10 and the ICD-10-CM?
The term “ME/CFS” does not exist in the ICD-10 or ICD-10-CM, even though the US federal agencies and numerous medical education providers have adopted the term. The only terms that exist are “ME” and “CFS.”
The WHO classifies ME and CFS in the neurological chapter of both ICD-10 and ICD-11 under the lead term “postviral fatigue syndrome (PVFS).” The US also classifies ME in the neurological chapter of ICD-10-CM under PVFS. However, when the ICD-10-CM was rolled out in the US in 2015, the US relocated CFS to the Symptoms chapter and gave it the same code as the symptom of “chronic fatigue.” The US is the only country in the world to have done this. This is not aligned with either ICD-10 or ICD-11.
Attendees at a previous meeting on ICD-10-CM held by the National Center for Health Statistics (NCHS), the CDC group that manages ICD-10-CM, stated that ME is seldom seen in medical records. The vast majority of US doctors use the term “CFS.” And if a doctor were to record a diagnosis of ME/CFS, the person assigning the code in the medical record would have to choose either the code for CFS or for ME since there is no code for ME/CFS. As a result, the vast majority of Americans diagnosed with ME/CFS in the US will end up with the code for the symptom of “chronic fatigue, unspecified” in their medical records instead.
- What difference does the lack of an ICD-10-CM code for ME/CFS make?
This makes it impossible to track and report on the mortality and morbidity of cases of ME/CFS separate from the symptom of non-specific chronic fatigue due to any cause. This likely impedes insurance reimbursement, generation of statistics on disease burden and outcomes, the medical perception of ME/CFS. And it also makes it virtually impossible to identify ME/CFS cases in retrospective research using electronic health records, such as that being done for Long COVID.
- Who does this affect?
Before the pandemic, this affected an estimated 1 to 2.5 million Americans with ME/CFS, leaving them effectively lost in the medical system.
These numbers are expected to grow significantly, given the risk of people developing ME/CFS following an acute COVID-19 infection. While no firm estimates exist, previous studies suggest that as many as 10-12% of people can develop ME/CFS following an infection. This could translate to millions of new cases of ME/CFS. Some Long COVID patients, those experiencing prolonged symptoms post-COVID, have already been diagnosed with ME/CFS. And emerging clinical care guidance for Long COVID is already recognizing the potential link.
- Why has this problem not been addressed before?
Proposals were submitted to NCHS in 2011, 2012 and again in 2017 to move CFS back to the neurological chapter. But these proposals were rejected because of lack of stakeholder consensus on how to resolve this problem. Stakeholders to the NCHS process include groups such as the medical community, the patient community, and hospital and coding associations.
Examples of areas of lack of consensus included:
- Whether or not CFS should be moved back to the neurological chapter at all since it has been used as a wastebin diagnosis and/or because it has not been proven to be specifically neurological.
Note that WHO has said terms should not be moved from one place to another unless robust science supports that decision. This is in part why ME and CFS remain in the neurological chapter in ICD-11, since it was located there in ICD-10.
- Whether CFS and ME are the same thing and should have the same code or are different and need different codes. Whether doctors will be confused if CFS and ME have different codes
- Whether CFS belongs under postviral fatigue syndrome since it is not always postviral
- Whether SEID should be added (discussed in the 2017 meeting but the term has not been adopted)
- What is being proposed now to address the lack of an ICD-10-CM code for ME/CFS?
In December 2020, seven organizations, listed below, submitted a proposal to NCHS asking for three primary changes:
- Change the lead term from “postviral fatigue syndrome” to “postviral and other related fatigue syndromes” because ME can be triggered by both viral and non-viral causes
- Note that WHO rules require that the words in the current title, “postviral fatigue syndrome,” are also in the new title so options for this lead term are limited.
- Establish different codes for ME and PVFS since PVFS is always postviral and ME can be triggered by other causes. ME/CFS will use the same code as ME.
- Add the terms “myalgic encephalomyelitis/chronic fatigue syndrome” and “ME/CFS” as “inclusion” terms (essentially synonyms) of the term “myalgic encephalomyelitis”
The submitted proposal focused on getting the term ME/CFS added as doctors are using that term and it needs to be in the ICD-10-CM. It dd not ask to have the term “chronic fatigue syndrome” moved to the neurological chapter because stakeholders rejected the various proposals for resolving this in the last three proposals.
The seven organizations that submitted the proposal to NCHS are:
The International Association for Chronic Fatigue Syndrome/Myalgic Encephalomyelitis, #MEAction, Open Medicine Foundation, Solve M.E., Massachusetts ME/CFS & FM Association, Minnesota ME/CFS Alliance, and Pandora Org,
- When will this change to ICD-10-CM be implemented if it is approved?
This proposal is scheduled to be discussed at the ICD-10-CM Coordination and Maintenance Committee meeting on September 14-15, 2021. After the meeting, there will be an opportunity for public comment prior to a final decision by NCHS. If the proposal is accepted, the change would be implemented in October 2022.
- Does this resolve the problem? If no, why not and what else needs to be done?
No, this does not fully address the problem...
First, the proposal submitted by the organizations does not address how CFS is classified in the US ICD-10-CM.
Second, ME/CFS patients who currently have a CFS diagnosis will have to have the new code added to their medical record in order for them to be properly tracked. If not done, they will continue to be subsumed under the symptom of “chronic fatigue, unspecified” in medical records.
- Does this impact people with Long COVID?
Some people with Long COVID may develop and be diagnosed with ME/CFS. This will ensure they are correctly tracked and not dumped into the “chronic fatigue, unspecified” bucket.
- Does this affect the ability of people with ME/CFS to get disability?
It is difficult to get disability for ME/CFS in the US. But this change should not impact that. The 2014 Social Security Administration (SSA) ruling for this disease used the term “CFS” but referenced the 2003 ME/CFS Canadian Consensus Criteria and the 2011 ME International Consensus Criteria. Since then, SSA has published the 2018 guide for healthcare professionals that refers to the disease as Myalgic Encephalomyelitis/Chronic Fatigue Syndrome.
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