• Public Affairs

  • ACOEM Supports NIOSH ICD-10 Proposal

    Janurary 13, 2013

    Donna Pickett, MPH, RHIA
    Co-Chair, ICD-9-CM Coordination and Maintenance Committee
    National Center for Health Statistics
    ICD-9-CM Coordination and Maintenance Committee
    3311 Toledo Road, Room 2402
    Hyattsville, Maryland 20782

    Dear Ms. Pickett:

    The American College of Occupational and Environmental Medicine is pleased to submit this letter in support of the proposal, External Cause Codes for Work-related Musculoskeletal Disorders Caused by Ergonomic Hazards, being presented during the ICD-10-CM/PCS Coordination and Maintenance Committee Meeting on March 19-20, 2014. Our understanding is that this proposal is being submitted as part of a collaborative effort between the National Institute for Occupational Safety and Health and experts from the Ohio Bureau of Workers’ Compensation, the California Department of Public Health, the University of California, San Francisco, University of California, Berkeley, and the Institute of Work and Health.

    ACOEM supports the proposed external causation categories for: 1) exposure to vibration; and 2) overuse and strenuous or repetitive movements or postures and the new codes for each category. We support these changes because these mechanisms are not available among the current external causation categories. Work-related musculoskeletal disorders (MSD) are a group of diagnoses that are defined by both the diagnosis itself in combination with exposure to one or more ergonomic hazards. As a group, MSDs are the most common cause of work-related injuries. Adding the proposed codes is necessary for accurate and correct classification of MSDs. Without these codes it is not possible to identify or track MSDs using ICD-10-CM.

    However, by endorsing these codes ACOEM is not endorsing all of the mechanisms listed as having strong evidence supporting their relationship to pathological conditions. These exposures have been studied as possibly contributing to treatable conditions and as such the creation of these codes can provide data for valuable epidemiological studies.

    ACOEM urges the National Center for Health Statistics to implement this change during the partial code freeze and prior to the October 1, 2014, ICD-10-CM implementation to allow for a smooth transition to the new system.

    Thank you for your consideration of  these comments regarding the External Cause Codes for Work-related Musculoskeletal Disorders Caused by Ergonomic Hazards proposal. If you have any questions, please contact Pat O’Connor, ACOEM’s Director of Government Affairs at 202/223-6222.


    Ronald R. Loeppke, MD, MPH, FACOEM