Response to SSD Being Added to the ICD-10-CM
November 15, 2013
National Center for Health Statistics – CDC
3311 Toledo Rd
Hyattsville, MD 20782
Re: Addition of Somatic Symptom Disorder into the ICD-10-CM Tabular List and Alphabetical Index in regards to the proposals on September 18- 19, 2013 meeting of the ICD-9-CM Coordination and Maintenance Committee.
Specifically referenced: Diagnostic Agenda, Page 45: Additional Tabular List Inclusion Terms for ICD-10-CM
Add Somatic symptom disorder to ICD-10-CM Tabular List under F45 Somatoform Disorders as inclusion term to F45.1 Undifferentiated somatoform disorder.
Add Somatic Symptom Disorder [SSD] to ICD-10-CM Alphabetic Index. – Requestor for proposal: Unspecified
We are writing to voice our objection and utmost concern for the inclusion of the APA’s newly defined Somatic Symptom Disorder into the ICD-10-CM for the following reasons:
- the benefit of any new or changed diagnosis must always far outweigh the risk
- it is a dangerous assumption that medically unexplained means there is no further need to discover new disease because we have identified any and all illness; medically unexplained is not synonymous with medically unexplainable
- the Somatic Symptoms Diagnosis is in fact a denial to medical care
- the SSD diagnosis is rarely, if ever, removed
- SSD is most often used by General Practitioners with no mental health training, yet it is a mental health diagnosis
- no supporting clinical or written references for the validity of Somatic Symptom Disorder as a new disorder term was published in the Diagnosis Agenda for the Public meeting (In a paper published in the Journal of Psychosomatic Research, September 2013, the SSD work group concedes the lack of clinical evidence for its new construct and acknowledges the “small amount of validity data concerning SSD”; “that much remains to be determined” about the utility and reliability of the specific SSD criteria and its thresholds when applied in busy, general clinical practice, and there are “vital questions that must be answered” as they go forward)
- there was no discussion or presentation of the SSD proposal during the course of the Public meeting by anyone
- Somatic Symptoms Disorder runs a high risk of misinterpreting a patients desperate cries for medical care as illness anxiety and therefore mislabeling physical illness
The Somatic Symptoms Diagnosis has created much controversy. Many patients, carers, advocates, and physicians have found this “dust bin” diagnosis to be very dangerous (as per many of the DSM-5 comments that were voiced). Allowing an over inclusive dust bin diagnosis to exist is negligent.
The Somatic diagnosis is rarely removed from a patient chart as a diagnosis – putting a patient at high risk for the duration of their life. It also may have a grave effect on a parent not following their parental instincts to seek medical attention for their children out of fear of being “overly” anxious when their child is ill.
We do not deny a small percentage of people who may experience such anxiety to being ill. Those who are deemed to be debilitated by their medical anxiety can be treated and their doctor can still be compensated if the patient is coded for an anxiety disorder. Medical anxiety should not either be a hidden diagnosis in patients chart nor made when a doctor does not know what is wrong with their patient. Illness anxiety would only be treatable if both the diagnosing physician and the patient recognize the disorder and both see the need for treatment.
The SSD diagnosis opens any doctor who uses it up for liable medical malpractice because of lack of guidelines. It is a diagnosis based on a subjective opinion not science based evidence.
Science ceases to be science when there is no longer a desire to search for the truth. Practicing medicine should be a science. Patient trust decreases in the medical community when a harmful and a dangerous invented diagnosis makes its way into the coding books such as the ICD.
We thank you for your consideration,