Submission to the Working Group


Draft Clinical Practice Guidelines on the Evaluation of Prolonged Fatigue and the Diagnosis and Management of Chronic Fatigue Syndrome



A Review of Draft Version 1


Jim Oakley

January 1998


----------------------------------------

Contents


1 Introduction


2 Overview


3 Strengths


4 Major Areas for Improvement

Diagnostic Criteria
CBT and Graded Aerobic Exercise
Management of Sleep Disorder
Natural History
Treatment and Placebo Effect
Pathophysiology
Symptoms
Diet
Heterogeneity
Support Groups
Depression
Nomenclature
References
Consumer Input


5 Minor Areas for Improvement


6 Conclusion

----------------------------------------

1 Introduction

I would like to thank the Working Group for the significant effort that has gone into producing the Draft Clinical Practice Guidelines. I have reviewed the guidelines in detail, and this submission documents my response. I was unable to use the evaluation form supplied with the draft guidelines since it did not allow adequate reporting of the nature and extent of my comments.

As with any draft, I believe corrections and refinements are needed to the guidelines so that they can serve their intended purpose in the best possible manner, and so that they accurately reflect the evidence in the published literature for all topics discussed. To the best of my ability I have focused my comments on the contents of the guidelines and the published medical literature. I believe that this approach is appropriate for a review of an evidence-based document. I have avoided philosophical discussions, speculation and emotional arguments.

I have undertaken this review in a spirit of goodwill and cooperation, and have documented my comments in the hope that they will help to strengthen the Working Group's already substantial efforts. I have divided this submission into five sections: Overview, Strengths, Major Areas for Improvement, Minor Areas for Improvement, and Conclusion.




2 Overview

The draft guidelines document is very attractive and comprehensive, and has the potential to be the benchmark by which other similar documents are judged. Most relevant topics are covered, and the content is supported by a large number of references from the mainstream medical literature. The guidelines will be a valuable resource for the medical profession in Australia for the next few years.

It must be recognised that, once published, the guidelines will become the 'bible' of CFS in this country. The final document will, for the foreseeable future, be the authoritative source on CFS for general practitioners and other health service providers, government departments, insurance companies, schools and employers. The guidelines will potentially be used as a source of evidence in court cases involving people with CFS. The Working Group thus has an enormous professional and ethical responsibility to minimise the chances of the guidelines being used as a basis for the unfair, discriminatory or harmful treatment of people with CFS.


* Criteria for evidence-based guidelines
I believe it is imperative that the guidelines fulfil the following criteria:

1) They must present a fair and balanced view of the published literature relating to the topics which are covered. They must accurately reflect the results and findings of the referenced studies.

2) The principles used for developing the guidelines must be applied firmly and consistently at all times (eg. quality of evidence ratings, exclusion of data from studies using a single case series with no control group, etc). 3) They must be worded in such a way that minimises opportunities for non-experts to draw inappropriate conclusions about the topics and evidence that are presented.

4) They must be free of typographical and referencing errors, which ultimately reduce the utility of the document.

In many instances, the guidelines satisfy these criteria very well. I have, however, identified a number of important areas where these criteria are not satisfied, which causes me great concern. My concerns, and the evidence to support them, are detailed in this submission. I request that the Working Group carefully reviews all of the issues and points that are raised, so that they can be fully addressed before the final document is published.




3 Strengths

The draft guidelines have many strengths, which together make this document one of national and (potentially) international significance. In my view, the strengths are:

Presentation and Format
The guidelines document is particularly well presented. Boxes and diagrams have been used to maximum effect, there is plenty of white space, and the text is easily readable. When printed in colour, the presentation will be further enhanced. This is important because, regardless of the content of the guidelines, if they are not presented in an attractive and easy-to-read manner, they will be only partially read, or even ignored, by many of the intended readership.

Clinical Overview
This is concise and pertinent, and provides a good overview of the subject.

Content
The information in the body of the document is presented in a logical order, is very comprehensive, and is generally well supported by references. Most relevant issues of interest to general practitioners are covered.

References
An extensive list of studies is referred to in the text, consistent with the requirements for an evidence-based document. Providing references is important since it gives credibility to the statements in the text. General practitioners can then feel confident that the guidelines contain the best available information. The list of references is an important resource in its own right.

Illness Severity
The guidelines treat CFS as a serious illness, and do not attempt to trivialise the suffering of people with the disorder.

Diagrams
The diagrams are generally well thought out, and in all cases convey their message with clarity. The diagram in Box 5.5 is outstanding.

Text Boxes
The text boxes also provide a valuable dimension to the guidelines, by summarising the important points in the body of the text. Boxes 4.1 and 4.2 are extremely useful in that they summarise a large amount of information, allowing readers to quickly obtain a clear idea of the merits of different treatments which have been scientifically tested in people with CFS. Boxes 5.1-5.4 are also excellent for the concise overview they provide of CFS research findings.




4 Major Areas for Improvement

This section deals with the non-trivial aspects of the guidelines which I believe could be improved. Where I have made explicit or implied recommendations or suggestions for change, the text is underlined for ease of identification. References are the same as those presented in the guidelines; in cases where a reference is not mentioned in the guidelines, the full citation is included where it first appears in this submission.



Diagnostic Criteria

* Use of research diagnostic criteria
The Working Group has selected the most recent Centers for Disease Control and Prevention (CDC) diagnostic criteria (Fukuda et al. 1994) to define CFS in a clinical setting. This is expressly stated in the guidelines in Box 1 on page 1, and separately on pages 5 and 6. There are two important consequences of this decision, which are described below.

The 1994 CDC diagnostic criteria were never intended for use in a clinical setting, but were designed to help identify more uniform groups of patients for research studies. It is stated in the published paper (Fukuda et al. 1994, page 956) that:

"the overall purpose of the proposed conceptual framework and guidelines is to foster a more systematic and comprehensive approach toward the collection of data about the chronic fatigue syndrome and similar illnesses."

On 27th September 1993, the CDC in Atlanta hosted a public meeting to review the case definition for CFS, in advance of publishing the revised case definition in 1994. One of the researchers who gave a presentation was Dr Ian Hickie, who noted the need for separate clinical and research criteria. According to The CFIDS Chronicle of November 1993, page 7, Dr Hickie said:

"There are different needs in criteria sets. One is a clinical one. It is inherently patient-focused. It's about disability. It's about issues of duration and it's tied up in the issues related to the health care system...Quite separately, one needs to have research criteria that allow specific questions to actually be asked that match hypotheses and criteria. So we would strongly recommend that you can't simply come up with one size fits all. You've got to have some separation that allows the research to continue dealing with fundamental issues and similarly allows the patients to get on with their treatment and not feel that they have to fit the research criteria in order to receive care and disability."

The 1994 CDC diagnostic criteria were devised by researchers including those in the International Chronic Fatigue Syndrome Study Group. Following the publication of the paper of Fukuda et al., one member of the study group, Dr Jonathan Rest, wrote that:

"reliance on the new definition to apportion health insurance benefits or make other socially relevant decisions may be utilising the definition in ways inappropriate to its intent." (The CFIDS Chronicle, Fall 1995, page 51).

As a result of the Working Group's decision to adopt CFS research criteria for clinical application by general practitioners, the following issues arise:

1) Many people who currently have a diagnosis of CFS will now no longer have CFS, but will have 'chronic fatigue' (or more correctly, idiopathic chronic fatigue). Similarly, in future, many people who would have received a diagnosis of CFS will be diagnosed with 'chronic fatigue'.

2) Many of the studies referred to in the draft guidelines as studies of CFS are actually studies of 'chronic fatigue', since the patients were diagnosed according to either Oxford or Australian diagnostic criteria, which are not as exclusive as the 1994 CDC case definition for CFS.

The logical approach for the Working Group is to adopt a broader definition of CFS for clinical purposes. There is little merit in diagnosing some people with CFS and some with chronic fatigue simply on the basis of the presence or absence of some symptoms when, with the current state of knowledge, the distinction is arbitrary. The distinction is present for research purposes, but has no meaning in clinical practice. The adoption of a broader set of diagnostic criteria would also help to justify the practice in the guidelines of referring to research studies employing Oxford or Australian diagnostic criteria as CFS studies, when some or many of the people in these studies did not meet the current CDC research criteria for CFS.

If the Working Group decides to keep the 1994 CDC case definition as the criteria for diagnosing CFS in general practice, then it is essential that readers of the guidelines are made fully aware that people with idiopathic chronic fatigue are not 'less sick' than people with CFS simply because their illness has a different name. People with idiopathic chronic fatigue should, on an as-needs basis, have access to the same medications, disability allowances, doctor support and other services as people with CFS who have similar levels of disability. The only place in the draft guidelines where this principle is alluded to is on page 5, where it is stated:

"Some people with severe fatigue syndromes will fail to meet the research diagnostic criteria for CFS but may still benefit from the assessment and intervention strategies described in these guidelines."

This one sentence is grossly inadequate to protect the interests of those many people who have idiopathic chronic fatigue but who do not meet all the research criteria for CFS. It is important that this issue is presented more prominently in the guidelines, for example in a highlighted text box.


* Source of confusion
The classification of people who have clinically evaluated but unexplained chronic fatigue is handled poorly in the draft guidelines. A potential source of confusion about appropriate diagnostic categories arises in Box 1.1 on page 6 and in Box 2.2 on page 10. The information in the two boxes is not internally consistent, and is not consistent with the paper containing the most recent CDC case definitions for CFS and idiopathic chronic fatigue (Fukuda et al. 1994). The definitions, as given by Fukuda et al., are:

Prolonged fatigue: self-reported, persistent fatigue lasting one month or longer.

Chronic fatigue: self-reported persistent or relapsing fatigue lasting six or more consecutive months.

Idiopathic chronic fatigue: clinically evaluated, unexplained chronic fatigue that fails to meet criteria for the chronic fatigue syndrome.

Chronic fatigue syndrome: as per Box 1, page 1 of the draft guidelines.

Instead of four definitions, Box 1.1 lists only three definitions. The definitions are for prolonged fatigue, chronic fatigue, and CFS. The definitions of prolonged fatigue and chronic fatigue are consistent with that of Fukuda et al. There is no definition for idiopathic chronic fatigue in Box 1.1, but there is a definition for CFS.

In the paper of Fukuda et al., there is an important distinction between chronic fatigue and idiopathic chronic fatigue. Chronic fatigue refers to unevaluated chronic fatigue. Upon evaluation, patients with chronic fatigue will either be given an alternative diagnosis, a diagnosis of CFS, or a diagnosis of idiopathic chronic fatigue. Idiopathic chronic fatigue is similar to CFS, except that in this case patients do not meet all the symptom criteria for CFS.

The guidelines need to clearly define idiopathic chronic fatigue, because many people fit into this category. If the Working Group is using the term 'chronic fatigue' to mean idiopathic chronic fatigue, then the definition in Box 1.1 needs to be changed to include the words "unexplained by other medical or psychological conditions", and an explanation needs to be given in the text.

Problems with terminology also arise in Box 2.2 on page 10. On the flow chart, fatigue present for more than one month is labelled "persistent fatigue" instead of "prolonged fatigue". This is not consistent with the information in Box 1.1. I suggest that the title of Box 2.2 be changed to "Flow Chart for the Evaluation of Persistent Fatigue", where the word "persistent" has replaced the word "prolonged", because "prolonged fatigue" has its own restricted definition. It appears that on this flow chart the term 'chronic fatigue' refers to idiopathic chronic fatigue, since it has been evaluated and remains unexplained at six months. This is not consistent with the definition of chronic fatigue in Box 1.1 or in the paper of Fukuda et al. 1994.



Cognitive Behavioural Therapy (CBT) and Graded Aerobic Exercise Therapy

* Nature of studies
The experience and consequences of severe and/or long term CFS can be horrific. I support the use of any ethical management strategy, therapy or treatment for people with CFS which has been proved to be safe and efficacious. The central issue with CBT and graded aerobic exercise therapy is, of course, whether or not they have been 'proved' to be safe and effective.

My conclusion, on the basis of the published studies quoted in the guidelines in Box 4.1 on page 18, and again on page 20, is that CBT and graded aerobic exercise therapy should be regarded as separate treatments (they are in fact listed separately in Box 4.1). The reasons for this view are as follows:

1) The graded aerobic exercise in the study of Fulcher and White 1997 was much more regimented and controlled than the graded activity described in the CBT papers. For example, Fulcher and White employed an exercise physiologist to conduct clinic-based exercise and to prescribe home-based exercise. Patients were given ambulatory heart rate monitors to ensure they reached, but did not exceed, target heart rates. The focus of Fulcher and White's program was specifically on graded aerobic exercise, not graded activity. In the paper of Deale et al. 1997, graded activity includes activities as diverse as walking, reading, visiting friends or gardening.

2) In the last paragraph on page 1651 of their paper, Fulcher and White clearly regard their exercise treatment as separate to and different from CBT.

3) The study of Fulcher and White 1997 is the only one in which it is possible to assess the effect of graded exercise or graded activity on CFS. With the CBT studies, it is not possible to determine the relative contribution of graded activity to the improvement (or non-improvement) experienced by people with CFS who undertook CBT.

4) In support of this last point, the following statement appears in one of the studies (Deale et al. 1997, page 414) which reported benefit for people with CFS from CBT incorporating graded activity:

"However, further research is necessary in order to determine the efficacy of specific components in, and the optimal delivery of, cognitive behaviour therapy for chronic fatigue syndrome. The issues of who benefits from such treatment and how the response rate can be maximised merit further attention."


* Graded aerobic exercise therapy
It is essential that the quality of evidence ratings are applied firmly and consistently throughout the guidelines. In light of the comments above, I believe that graded aerobic exercise should correctly be given a quality of evidence rating of Level III-3. Graded aerobic exercise should be listed separately in Box 4.2 on page 19, and to be consistent with other Level III-3 treatments, the comments in the 'Recommendation for treatment use' column should be: "Not recommended, Further studies indicated".

In Box 4.2 under comments relating to CBT, it is stated that:

"Replicated studies show benefit of graded exercise component".

This statement is not correct and should be removed. Only one study has specifically examined graded aerobic exercise, and it is not possible with the CBT studies to determine how much influence, if any, graded activity had on the outcome of these trials.

On page 20 of the guidelines, referring to the study of Fulcher and White 1997, the following statement appears:

"Only one of the 66 people with CFS in this exercise study reported worsening of symptoms over the 12 months of the program." This statement is incorrect, and is a misinterpretation of the information in the box on page 1651 of Fulcher and White's paper. Four of the original 33 people in the exercise group dropped out during the twelve weeks of treatment. One of these four dropped out because he said the treatment made him worse. This is reported on page 1649 of Fulcher and White's paper under 'Treatment Results'. As can be seen from Table 1 on page 1649, one person out of the remaining 29 in the exercise group rated himself as worse after completing 12 weeks of treatment. This is also stated in the text on page 1649 under 'Treatment Results'. Similar results were found for the flexibility treatment group.

Thus by the time the 12 weeks of exercise treatment was completed, two people out of 33 (6%) had been adversely affected by the treatment. Follow-ups were conducted at three and 12 months after the completion of the exercise program. Fulcher and White state that, at the three month follow-up, 68% of people who completed the exercise program rated themselves as better. At the 12 month follow-up, 74% of patients who completed the exercise program rated themselves as better. No data are provided in the paper about how many people who completed the exercise program rated themselves as worse at these particular times. This was a crossover trial, and only 47 (not 66) people completed exercise therapy.

It can be seen then that the above quote on page 20 of the guidelines is incorrect and should be removed.

In the third dot point in the text box titled 'Management' on page 17 of the guidelines, it is stated that:

"Graded aerobic exercise is safe and effective for people with CFS (Level II)".

The evidence is Level III-3 as explained above, and the quoted statement cannot be justified on the basis of one study. It should be modified or removed. A similar statement on page 3 in the Clinical Overview should also be modified or removed. More trials are required to fully determine if this form of treatment is safe and effective for the general population of people with CFS. Furthermore, all the participants in the study of Fulcher and White 1997 were ambulatory at trial entry. Five people were unable to participate in the trial because they were too incapacitated to attend for outpatient treatment. It is not known how graded aerobic exercise therapy will affect people with more severe forms of CFS.


* Cognitive behavioural therapy
It is essential that the quality of evidence ratings are applied firmly and consistently throughout the guidelines. Two studies have found CBT to be beneficial for people with CFS (Sharpe et al. 1996, Deale et al. 1997), while two others have found no such benefit (Lloyd et al. 1990, Friedberg and Krupp 1994). The only quality of evidence rating that can be assigned to CBT is Level III-4. This rating is the same as that given by the Working Group to intravenous immunoglobulin G, where two studies showed benefit and two didn't (see Box 4.2, page 19).

In Box 4.2, for CBT, the level of evidence rating should be changed from Level II to Level III-4. The comments in the 'Recommendation for treatment use' column should be "Not recommended, Further studies indicated".

In the second dot point in the text box titled 'Management' on page 17, it says:

"Cognitive-behaviour therapy is effective for people with CFS (Level 1)". This statement cannot be justified, and should be modified or removed.

On page 26 of the guidelines, in the section headed 'How were these clinical practice guidelines developed?', it is stated that:

"Data from a single case series without control subjects provide little more than a stimulus for subsequent hypothesis testing. Such reports were not included in the systematic analysis of evidence upon which these guidelines are based."

The reference to the study of Butler et al. 1991 on page 20 should therefore be removed, since this study is a single case series without control subjects. Other CFS studies which had no control group have not been mentioned in the guidelines, so the paper by Butler et al. should be no exception.


* Context of studies
One of the weaknesses of the discussion in the guidelines about both CBT and graded aerobic exercise therapy is that the referenced studies are not put in context for the reader. It is not stated how sick participants were at trial entry, or how long they had been ill, and it is not stated how much improvement was made by treatment responders. Based on the discussion in the guidelines, general practitioners will have no real idea about what to expect if they implement a CBT or graded aerobic exercise program with their CFS patients.

In the studies which reported benefit for people with CFS who underwent CBT or graded aerobic exercise, the outcomes at long term follow-up were as follows: 74% improved (Fulcher and White 1997); 70% substantially improved (Deale et al. 1997); 60% significant improvement (Sharpe et al. 1996). This is not mentioned in the guidelines. Unless general practitioners study the referenced papers, they will have no idea that even in the 'positive' studies, anywhere from 26% to 40% of people with CFS did not improve significantly with these treatments. Some deteriorated (13% in the study of Sharpe et al. 1996).

The guidelines present CBT and graded aerobic exercise therapy almost as a panacea for CFS. General practitioners who adopt these approaches, and who are seduced by the upbeat mood of this section of the guidelines (and who do not refer to the original references), may tend to push their CFS patients to do more if they are not improving during and after treatment. This could be highly detrimental to some people with CFS.


* Can CBT and graded aerobic exercise therapy programs be implemented effectively and safely in general practice?

Effectiveness
The CBT and graded aerobic exercise studies referred to in the guidelines were carefully planned and conducted. The CBT programs were administered by psychiatrists or psychologists experienced in this therapy; the graded aerobic exercise therapy was supervised by an exercise physiologist. In the studies reporting benefit for people with CFS, there was significant contact time between patients and those providing the treatment: patients attended sessions at the clinic every week or fortnight, and attendance was required for between 12 and 16 sessions, depending on the study. For the CBT programs, each session was about an hour in length, and on a one-to-one basis. Literature was provided to the patients in some of the studies.

The obvious question that arises is whether general practitioners have the time and the expertise to treat their patients with CBT or graded aerobic exercise therapy. Poorly designed and conducted programs are likely to benefit no-one. It would seem sensible for these therapies to be administered by professionals who are experienced in the techniques (eg. psychiatrists or psychologists for CBT), and who can structure their working day so that one-hour sessions can be accommodated.

If it is the intention of the Working Group for general practitioners to implement behavioural therapies with their CFS patients, careful thought needs to be given as to how they can do this. A clear explanation of procedures will then have to be provided in the guidelines. If it is the intention of the Working Group for experienced psychologists or psychiatrists to administer behavioural therapies to people with CFS upon the recommendation of a general practitioner, then this must be stated explicitly in the guidelines in order to prevent half-baked, ineffective, or even harmful programs from being devised and used on people with CFS.

Safety
In each of the three trials which found benefit for people with CFS from CBT or graded aerobic exercise therapy, there were still some people in the active treatment groups whose health had deteriorated at the time of follow-up compared with at trial entry. In the study of Sharpe et al. 1996, deterioration occurred in 13% of the CBT group; for Deale et al. 1997, 11% were either worse or unchanged. For the graded aerobic exercise therapy of Fulcher and White 1997, 2 patients out of 33 (6%) were worse by the end of 12 weeks of treatment (one of whom was unable to complete the treatment).

Adverse outcomes were likely to have been minimised in the published trials because of the expertise of the people administering the treatments, and because the programs were carefully designed in the first place. In the hands of less experienced people, behavioural therapies for CFS are likely to be accompanied by higher rates of adverse outcome. This again emphasises the need for general practitioners to utilise competent and experienced therapists for the implementation of behavioural therapies in people with CFS.

It is also important to note that adverse outcomes can be serious. Even experienced psychiatrists working in multidisciplinary teams have caused major problems for people with CFS using behavioural therapies. Consider the words of Dr Ian Hickie (see Abbey 1993, discussion, page 256), who in 1992 told the Ciba Foundation Symposium on CFS that:

"in trials of cognitive behaviour therapy, we have made the mistake alluded to; we have taken CFS patients who were coping well, using their somatic form, and occasionally unleashed a disaster by attempting to move them to a psychological form. Some have become more self-destructive, so we have created a major problem."


* Model of persistent disability
The diagram in Box 4.4 on page 21 of the guidelines attempts to demonstrate how persistent disability arises in CFS, and how CBT can be used to break the "vicious circles". According to Box 4.4, people with CFS who have no CBT are likely to enter a spiral of disability perpetuated by depression, anxiety, social isolation and increased physical illness. This theory about how persistent disability arises is at odds with the natural history data in Box 3.2 on page 16, which show that many people with CFS improve over time in the absence of CBT. It is my experience that people are usually sickest in the early stages of CFS and that they gradually improve, without any CBT. Even people who are bedridden for several years eventually become more functional without any intervention in the form of CBT.

The model of CFS disability depicted in Box 4.4, and espoused on page 20 of the guidelines, applies only to a minority of people with CFS. This should be made clear in the guidelines. Whether CBT is beneficial for people with CFS who are caught in the 'vicious circle', and whether it is beneficial for people with CFS whose health is stable or improving, can only be determined by future controlled trials.

It is also disingenuous to discuss persistent disability in CFS without any reference to the underlying pathophysiological processes. It is possible that in some or most people with CFS, the physical disease process (rather than psychological/behavioural/social factors) plays a very major role in causing persistent disability. With the current state of knowledge about CFS, there is no way that biological aspects can be discounted. This should be acknowledged prominently in the guidelines.

In Box 4.4 under the minor heading 'Education and Support', the second dot point says:

"encourage return to work, social activities, physical activity".

This should only be done after reference to the patient's level of health. For example, it is pointless encouraging someone to return to work if they are not well enough to attend. This will only cause additional problems. The guidelines should avoid catch-all statements, and should continually emphasis to readers that each patient should be treated according to his or her level of health and circumstances.


* How should CBT and graded aerobic exercise therapy be presented in the guidelines?
Based on the correct level of evidence ratings for these therapies (see above), there should be minimal discussion on CBT and graded aerobic exercise therapy in the guidelines, since at this stage there is not enough evidence to recommend them for use in a clinical setting. This approach is consistent with that applied in the guidelines to other treatments which have the same level of evidence ratings.

However, symptomatic drug therapy is currently used widely in the management of CFS, and its continued use is endorsed on pages 3 and 22 of the draft guidelines. This has been done in the absence of any proven benefit for these treatments in people with CFS; in fact, in most cases no trials have been done. General practitioners would essentially have nothing to offer their CFS patients if the use of unproven symptomatic treatments was discontinued.

The question then arises as to whether CBT and graded aerobic exercise therapy should be completely discarded until indisputable evidence of their benefit or otherwise for people with CFS is published. I have noted the high positive response rate to graded aerobic exercise in the trial of Fulcher and White 1997, and the fact that this form of therapy has been used to reduce incapacity and symptoms in conditions such as post-polio syndrome, chronic back pain and fibromyalgia.

I have also noted the high positive response rates to CBT in the controlled studies of Deale et al. 1997, and Sharpe et al. 1996. In particular, the results reported in Table 4 of the paper by Deale et al. are interesting. At the six month follow-up interview, people with CFS who underwent CBT were asked about their opinions of the treatment. 78% were satisfied or very satisfied with the treatment outcome, while 96% thought the treatment was useful or very useful. This appears to be a good endorsement of the CBT approach used in this trial.

Future trials may (or may not) demonstrate conclusively that CBT and/or graded aerobic exercise are beneficial for many people with CFS. So that people with CFS who would like to try these therapies in the hope of making some improvement in their condition are not denied the opportunity, I suggest that the Working Group could adopt the following approach:

1) State that the use of CBT and graded aerobic exercise therapy in CFS remains experimental, and that conclusive results await further trials.

2) State clearly that patients should never be coerced or pressured into undertaking these unproven therapies, and that there should be no expectation for them to do so.

3) Endorse the use of these therapies in cases where both patient and doctor would like to trial them.

4) Put more emphasis on the following statement which appears on page 20 of the guidelines:

"The physical activity programs are individually designed to take account of the patient's current level of disability and avoid immediate worsening of symptoms."



Management of Sleep Disorder

I recognise that sleep disorder occurs commonly in people with CFS, as reported in the literature. I agree in general with the principles of sleep management, and accept the desirability of normalising circadian rhythms in people with CFS. However, I am concerned about two of the recommendations made on page 21 of the draft guidelines (which also appear on page 3 in the Clinical Overview).


* Restricting the sleep period to about eight night-time hours
People with CFS often sleep significantly longer than eight hours as a result of the disease process, ie. they are not sleeping longer by choice, but as a result of the pathophysiological processes occurring in their bodies. People who are particularly ill may 'need' the most sleep. It is silly to recommend that sleep should be restricted to about eight hours per night. This is like saying that muscle pain or headaches should be restricted to eight hours per day. People who are very sick with CFS will simply fall asleep during the day if they are forced to wake up after only eight hours of sleep at night; for these people, sleeping is not a matter of choice.

It is stated on page 21 of the guidelines that:

"In CFS, sleeping longer does not improve physical or mental functioning".

As far as I am aware, there are no published studies to support this statement. Furthermore, the figure of eight hours sleep per night is arbitrary. Many healthy people naturally sleep longer than eight hours per night. This part of the sleep guidelines should be replaced with a more general statement which, while encouraging the resumption of normal night-time sleep, does not prescribe a specific number of hours of sleep.

* Reducing or abolishing daytime naps
Again, this is a sweeping statement which does not take into account individual needs. Some people with CFS who do not sleep well at night need daytime naps simply to give them enough energy to be able to undertake their daily physical and mental activities. This also applies to some people with CFS who do sleep well at night. This guideline needs to be broadened to inform general practitioners that the individual circumstances of each patient should be taken into account before any drastic reduction in daytime sleeping is implemented.

It is also stated on page 21 of the guidelines that:

"If people with CFS have a concurrent primary sleep pathology (eg. sleep apnoea), this requires specific intervention."

However, on pages 9, 11 (Box 2.3), and 12 of the guidelines, sleep apnoea is listed as a specific alternative diagnosis to CFS, ie. one that excludes a diagnosis of CFS. This is in conflict with the above statement on page 21. It needs to be clarified in the guidelines whether or not someone can have CFS and sleep apnoea concurrently, or whether the two diagnoses are mutually exclusive.

I also recommend that the guidelines should contain reference to the following recent paper on CFS and sleep disorder:

Morriss R K, Wearden A J, and Battersby L, 'The Relation of Sleep Difficulties to Fatigue, Mood and Disability in Chronic Fatigue Syndrome', Journal of Psychosomatic Research 1997; 42(6): 597-605.



Natural History

* Outcome of fatigue states
On page 15 of the guidelines, under the heading 'What is the outcome of fatigue states?', it is stated:

"The long term outcome of CFS has been evaluated mostly in people treated within tertiary referral settings (Box 3.2). Such patient samples are biased towards chronic illness and limited patterns of recovery...Patient reports drawn from self-help group populations show similar biases (Sharpe et al. 1992)."

The paper of Sharpe et al. 1992 cannot be used to support this last sentence. Sharpe et al. found a correlation between functional impairment and membership of a patient organisation. Length of illness was not correlated with membership of a patient organisation. On the basis of this evidence it is unfair to say that patient reports drawn from self-help groups are biased towards chronic illness.

In addition, there is only one reference given in the guidelines (ie. Sharpe et al. 1992) which refers to the characteristics of people who are members of CFS/ME self-help groups. It is misleading to talk about "patient reports" as if there were multiple papers dealing with this subject. If there are in fact more papers, they should be referenced so that readers can assess the quality of the evidence for themselves.



On page 15 of the guidelines, referring to the study of Wilson et al. 1994b, it is also stated that:

"During follow-up, patients were very unlikely to develop other medical disorders (2%) but a significant number did develop other psychological disorders (19%), notably major depression and anxiety. Similar outcomes were confirmed in several other retrospective studies from tertiary referral centres."

It is stated clearly by Wilson et al. 1994b, that 19% of the 103 people in this study had an alternative primary psychiatric diagnosis at follow-up. This diagnosis then excludes a diagnosis of CFS. It is quite possible that some or all of these 20 people were misdiagnosed in the first place, and never should have been included in a study of chronic fatigue syndrome. The wording in the guidelines quoted above implies that these patients developed psychological disorders that were concurrent with their CFS, which is not an accurate reflection of the findings of Wilson et al. It should be clearly stated in the guidelines that these 20 people had an alternative primary psychiatric diagnosis, not a concurrent psychological or psychiatric condition.

Table II in the study of Wilson et al. lists the alternative primary psychiatric diagnoses of the 20 patients as: personality disorder with somatoform disorder (7); primary somatisation disorder (3); recurrent unipolar depressive disorder (6); anxiety disorder (3); schizophrenia (1). It is hardly justifiable for the guidelines to use the words "notably depression and anxiety". Why notably? Furthermore, if similar outcomes were confirmed in several other retrospective studies, then these studies should be referred to on page 15.

In the FAQs box on page 4 of the guidelines, under the heading 'How long will it take to recover?', it is stated that:

"people with CFS who have been ill for less than two years have a high likelihood of recovery within the following two to three years."

There is no evidence to support this statement in the papers listed in Box 3.2 on page 16. As for the studies listed in Box 3.1 on page 16, all participants had been fatigued for less than six months at the time of study entry and, in the studies with adults, follow-up was a maximum of 15 months. There is thus no information on how people with CFS who have been sick for one-to-two years fare over the subsequent two or three years. The sentence above should be revised or removed.


* Factors delaying recovery
Of the eight studies on the natural history of CFS listed in Box 3.2 on page 16 of the guidelines, only three (Sharpe et al. 1992; Wilson et al. 1994b; Vercoulen et al. 1996; and excluding Bonner et al. 1994 due to very small sample size) examined predictors of poor outcome. The discussion in the guidelines on the natural history of CFS would be considerably strengthened with the inclusion of references to the two large studies listed below, both of which also examined predictors of poor outcome:

Bombardier C H and Buchwald D, 'Outcome and Prognosis of Patients with Chronic Fatigue vs Chronic Fatigue Syndrome', Archives of Internal Medicine 1995; 155: 2105-2110.

Ray C, Jefferies S, and Weir W R C, 'Coping and Other Predictors of Outcome in Chronic Fatigue Syndrome: A 1-Year Follow-Up', Journal of Psychosomatic Research 1997; 43(4): 405-415.

Table 1 overleaf documents the main findings of the five studies that have examined predictors and associations of outcome in CFS (including the two studies listed immediately above). These five studies all included people who met one of the published sets of CFS diagnostic criteria. They are by far the most comprehensive studies of their kind, and each included more than 100 patients. Other follow up studies are reported in Joyce et al. 1997. Of these, the study of Clarke et al. 1995 was also very comprehensive, but has not been included here since no published case definition was used for inclusion of patients, and the sample size - particularly for those who did meet CDC or NIH CFS criteria - was relatively small.

It can be seen from Table 1 that the factors that are consistently associated with poor outcome, for which there is little or no conflicting evidence, are:

* emotional disorder at follow-up
* high levels of fatigue or functional impairment at entry
* a low sense of control over symptoms at entry

Emotional disorder at follow-up was found to be associated with poor outcome in the studies of Sharpe et al. and Bombardier et al.; Wilson et al. found that an alternative primary psychiatric diagnosis at follow-up was associated with poor outcome. The data of Vercoulen et al. indicate a positive correlation between poorer psychological wellbeing at follow-up and poorer functional status, but it is not stated if the apparent association reached significance. Ray et al. did not measure emotional disorder at follow-up.

Levels of levels of fatigue and functional impairment at entry were found to predict poor outcome in the studies of Vercoulen et al. and Ray et al. These parameters were not measured at entry in the other three studies. Similarly, Vercoulen et al. and Ray et al. found that having a sense of lack of control over symptoms, or a poor internal locus of control, was associated with poor outcome. The other three studies did not measure this parameter.

The factors that are consistently found to be not associated with poor outcome, and for which there is little or no conflicting evidence in Table 1, are:

* age
* gender
* emotional disorder at entry.

Age, whether at study entry or illness onset, was found to have no association with outcome in CFS in all of the studies in Table 1. Bombardier et al. found that older age at study entry predicted poorer outcome in a group of people with chronic fatigue, but this finding did not apply to the CFS group in the same study. In the review of Joyce et al. 1997, four out of eight studies (not four out of six as stated by Joyce et al.) found that increasing age was associated with poorer outcome. The four that did find an association included the study of Bombardier et al. mentioned above, and the study of Hinds and McCluskey 1993, which simply found that patients under 20 years of age had a better outcome. The weight of evidence clearly supports the contention that older age does not predict poorer outcome.

Gender has never been found to predict poorer outcome, and emotional disorder at study entry was found in four studies in Table 1 to have no association with outcome.



============================================================

Table 1: Summary of Findings of Studies on the Natural History of CFS

--------------------------------------------------

Paper: Sharpe et al. 1992
Number of Participants: 144
Duration of Follow-Up (Months): Median: 12, Ave: 15#

Predictors/Associations of Poor Outcome:
At follow-up only:
* Belief in a viral cause
* Avoiding alcohol
* Belonging to a self-help organisation
* Current emotional disorder

Factors Not Associated with Poor Outcome:
* Age
* Gender
* Marital status

----------------------------------------

Paper: Wilson et al. 1994
Number of Participants: 103
Duration of Follow-Up (Months): 38

Predictors/Associations of Poor Outcome:
* Disease conviction at entry
* Primary psychiatric diagnosis at follow-up

Factors Not Associated with Poor Outcome:
* Age at illness onset
* Duration of illness
* Premorbid psychiatric diagnoses

----------------------------------------

Paper: Bombardier et al. 1995
Number of Participants: 226 (CFS)
Number of Participants: 216 (CF)
Duration of Follow-Up (Months): 18

Predictors/Associations of Poor Outcome:

CFS
* Dysthymia at follow-up

CF
* Older age at entry
* Longer duration of symptoms
* Lifetime history of dysthymia

Factors Not Associated with Poor Outcome:
For CFS and CF
* Gender
* Psychiatric diagnoses at entry

----------------------------------------

Paper: Vercoulen et al. 1996
Number of Participants: 246
Duration of Follow-Up (Months): 18

Predictors/Associations of Poor Outcome:
At entry:
* High fatigue severity
* Lack of control over symptoms
* Functional impairment

Predictors of Improvement
At entry:
* Sense of control over symptoms
* Lower fatigue severity
* Shorter duration of illness
* Relative absence of physical attributions

Factors Not Associated with Poor Outcome:
At entry:
* Age
* Physical attributions
* Level of psychological wellbeing
* Sleep problems

----------------------------------------

Paper: Ray et al. 1997
Number of Participants: 137
Duration of Follow-Up (Months): 12

Predictors/Associations of Poor Outcome:
At entry:
For impairment at follow-up:
* Functional impairment
* High level of fatigue
* Illness duration
* Internal locus of control

For fatigue at follow-up:
* Fatigue
* Cognitive difficulties
* Information seeking

Factors Not Associated with Poor Outcome:
At entry:
* Age
* Emotional distress
* Depression
* Illness attribution

--------------------------------------------------

#Average calculated from Table 1 on page 149 of paper by Sharpe et al. 1992.

============================================================

On page 15 of the guidelines, it is stated that:

"The factors associated with a poorer outcome include older age, concurrent psychiatric disorder, and the person's belief that the illness is purely physical in origin."

As discussed above, it is not correct to claim that older age is associated with poorer outcome. It is, however, correct to say that concurrent psychiatric disorder is associated with a poor outcome. The third item, ie. the person's belief that the illness is purely physical in origin, cannot be justified on the basis of the evidence in Table 1.

In Table 1, it can be seen that the studies of Sharpe et al. and Wilson et al. found that belief in a physical cause of the illness was associated with poorer outcome. In the study of Sharpe et al., however, the belief was assessed only at follow-up, and (as pointed out by the authors themselves) was thus not predictive. The studies of Vercoulen et al. and Ray et al. found that illness attributions were not predictive of poor outcome (eg. higher fatigue severity). Thus the level of evidence for this parameter is Level III-4.

Vercoulen et al. did find that physical attributions were predictive of improvement (p<0.05), but this was a small influence compared with the correlation that sense of control over symptoms had with improvement (p<0.0001). In the same study, lack of sense of control over symptoms was also predictive of fatigue severity (p<0.01), whereas physical attributions were not (as mentioned above). These data are in Tables 2 and 3 on page 492 of Vercoulen's paper. In the study of Ray et al., a low internal locus of control was predictive of impairment (p<0.03). This parameter is very similar to the sense of control parameter of Vercoulen et al. The level of evidence to support the predictive qualities of this parameter is therefore Level II.

Table 2 below summarises the levels of evidence for the predictors/associations of outcome recommended here for inclusion in the guidelines, and those which are currently in the draft guidelines.

Data with a higher level of evidence should take precedence over data with a lower level of evidence. The wording on page 15 of the guidelines should be changed to reflect the recommendations contained in Table 2, to be consistent with the evidence in the literature. The fourth dot point in the text box titled 'Natural history' on page 15 also needs to be revised in light of the above evidence.


============================================================

Table 2: Predictors and Associations of Poor Outcome in People with CFS
----------------------------------------

Recommended: Emotional disorder at follow-up
Evidence Level: Level II
Draft Guidelines: Older age
Evidence Level: Level III-4 (at best)
----------------------------------------
Recommended: High levels of fatigue or functional impairment at entry
Evidence Level: Level II
Draft Guidelines: Psychological disorder at follow-up
Evidence Level: Level II
----------------------------------------
Recommended: Low sense of control over symptoms at entry
Evidence Level: Level II
Draft Guidelines: Belief in a purely physical cause of CFS at entry
Evidence Level: Level III-4
============================================================


On page 20 of the guidelines, the following statement appears:

"Given that simplistic attributions of a purely physical basis for the illness are associated with poor outcome, people with CFS should be encouraged to adopt the widest possible view of the psychosocial, medical and rehabilitative strategies to promote recovery."

This is an excellent sentiment, but the wording referring to attributions of a purely physical basis for CFS being associated with poor outcome should be replaced with wording relating to lack of sense of control over symptoms being associated with poor outcome.

Information contained in the guidelines will invariably be conveyed to people with CFS. Telling medical practitioners that older age is associated with poor outcome is likely to be unhelpful for older people with CFS, since they can have no control over this factor, and believing this will increase their sense of powerlessness. This is quite apart from the fact that the weight of evidence indicates that older age is not associated with poorer outcome, as discussed above.

The third dot point in the text box on page 15 also needs to be revised. The natural history studies referred to in the draft guidelines and in this submission reported that anywhere from 17% to 64% of people with CFS improved over time, with a small additional percentage of people recovering completely. Three studies in Table 1 (Wilson et al. 1994; Bombardier et al. 1995; and Ray et al. 1997) reported that more than 60% of people with CFS were improved at follow-up compared with their condition at study entry. Improvement inherently encompassed psychological as well as physical dimensions. Vercoulen et al. 1996, reported that psychological wellbeing was significantly improved at follow-up in those who had recovered, in those who had improved, and even in those who had not improved. Thus the frequency and severity of psychological disorders in people with CFS reduces over time (Level I). It is not justifiable to say that people with CFS are at increased risk of developing psychological disorders!

The statement in the text box probably derives from an interpretation of the study of Wilson et al. 1994, but Wilson et al. found that 19% of people in their study had an alternative primary psychiatric diagnosis at follow-up, and it is thus quite possible that these individuals never had CFS in the first place. Furthermore, no other study in Table 1 reported alternative primary psychiatric diagnoses at follow-up. The common finding that emotional disorder at follow-up is associated with poor outcome is completely different to claiming that people with CFS are at increased risk of developing psychological disorders. In the absence of any evidence to support it, the third dot point in the text box on page 15 should be rewritten or removed.

The discussion relating to factors delaying recovery makes no mention of possible biological factors that may contribute to poor outcome. Just because the pathophysiological basis of CFS is unknown does not mean that it can be disregarded as an important influence on illness outcome. This should at least be acknowledged in this section of the guidelines. According to the data in Box 3.2 on page 16, people who have been sick with CFS for several have a very limited chance of regaining their pre-illness level of health over the subsequent few years. Psychological factors may explain some, but not all, components of persisting ill-health in people with CFS, and may play a larger role in some individuals than in others.


* Prolonged fatigue
With respect to prolonged fatigue, the following sentence appears on page 15 under the heading 'What factors may delay recovery?': "In a study of the relationship of non-specific viral illness and the development of prolonged fatigue in general practice, the person's view of the illness and the doctor's behaviour, rather than the viral infection, were predictive of the development of prolonged fatigue (Cope et al. 1994)."

This is a highly selective use of the available evidence. Another larger study (Wessely et al. 1995), which followed people from before the onset of a viral illness until six months after their initial presentation to a general practitioner, reported different results. Wessely et al. 1995 found that the person's view of the illness (ie. belief that fatigue was due to a physical cause) was not a significant predictor of fatigue at six months' follow-up. This is in direct contrast to the findings of Cope et al. 1994.

Wessely et al. also found that the presence of fatigue before presentation with a viral illness was a strong predictor of fatigue at six months' follow-up. This is also in direct contrast to the findings of Cope et al., who found that fatigue reported before the initial consultation was not associated with fatigue six months after the initial consultation.

The two studies cited here reported conflicting results on two important issues. The guidelines should either present a balanced view of the evidence, or they should avoid discussion of the results altogether.


* Text box 3.2, page 16
This text box needs to be expanded and revised. The studies of Bombardier et al. 1995, and Ray et al. 1997, should be included. The study of Calder et al. 1987, should be in moved into Box 3.1, since patients in this study had been ill for less than six months at the time of entry. In fact, 65% of patients were enrolled in Calder's study less than one month after becoming ill. This was a study of prolonged fatigue, not CFS.

Sample size should refer to those patients who were initially evaluated and who were evaluated at follow-up. For example, in the study of Wilson et al. 1994, of 139 people who were sent follow-up questionnaires, only 103 returned completed questionnaires. Thus the sample size was 103, as correctly reported in Box 3.2 of the guidelines. However, the same principle has not been applied to all other studies listed in the box. Box 3.2 in the guidelines needs to be updated with the information in Table 3 below:

============================================================

Table 3: Corrections to Sample Size Data in Box 3.2 on Page 16

----------------------------------------
Study: Calder et al. 1987*
Sample Size: 59 (not 65)
----------------------------------------
Study: Sharpe et al. 1992
Sample Size: 144 (not 177)
----------------------------------------
Study: Hinds and McCluskey 1993
Sample Size: 291** (not 393)
----------------------------------------
Study: Peterson et al. 1991
Sample Size: 62 (not 68)
----------------------------------------
Study: Vercoulen et al. 1996
Sample Size: 246 (not 298)
----------------------------------------
* This study belongs in Box 3.1
** According to Joyce et al. 1997
============================================================

The length of follow-up for the study of Sharpe et al. 1992, was not 24 months as stated in Box 3.2, but was a median of 12 months. The average length of follow-up, as calculated from Table 1 on page 149 of the paper by Sharpe et al., was 15 months.

The outcome figures in Box 3.2 are correct as given, because in the papers these data have been calculated according to the correct sample sizes listed in Table 3 above. The exception is the study of Calder et al. 1987. In this study, 36 people were still unwell at the 12 months' follow up. Thus (59-36) people, ie. 23 people had improved. This translates to a percentage improvement of (23/59x100)%, ie. 39%, not 45% as listed in Box 3.2.

In the study of Sharpe et al. 1992, it is stated that 13% of people had recovered at follow-up, but no figure is given in the paper for the overall percentage of people who improved. This can be calculated from Table 1 on page 149 of Sharpe's paper. Of the whole sample of 144 people, 93 (or 65%) remained functionally impaired at follow up, whereas 100% were functionally impaired at study entry. Thus 35% had moved from being functionally impaired to being not functionally impaired over the period of follow-up. Sharpe et al. state that 13% of patients regarded themselves as fully recovered. This means that (35-13)%, ie. 22% of people improved but did not recover. In Box 3.2 it is indicated that 63% of people in this study improved. This is not correct.

The correlates of persistent debility presented in Box 3.2 also need some revision. For the study of Sharpe et al., "limiting exercise" is listed as a correlate of persistent debility, but this variable did not reach significance when the logistic regression adjusted for confounding associations. "Limiting exercise" should thus be removed from Box 3.2. It also needs to be explained to readers of the guidelines that the other correlates found by Sharpe et al. which are listed in Box 3.2 were assessed only at follow-up.

Similarly with the study of Wilson et al. 1994, the correlation of persistent disability with psychiatric disorder (which should correctly be expressed as primary psychiatric disorder) was for psychiatric disorder at follow-up, not at study entry. The correlation with belief in a purely physical cause of CFS was for belief at study entry, not at follow-up.

In the study of Hinds and McCluskey 1993, the correlation of persistent disability was with age over 20 years (according to Joyce et al. 1997). In Box 3.2, the words "Younger age" should be replaced with "Age over 20 years".

As discussed previously, the study of Vercoulen et al. 1996 found that the correlates of persistent disability were (in order of importance): fatigue severity at study entry, lack of sense of control over symptoms at study entry, and functional impairment at study entry. None of these appears in Box 3.2, but "belief in a purely physical cause of CFS" does. This is not correct, and should be removed and replaced with the true correlates.


* Box 2, page 2
This box presents a graph of the number of patients with continuing symptoms of CFS versus time, under the heading of 'Model of natural history of chronic fatigue syndrome'. There are no references given to support this model, and the information in Boxes 3.1 and 3.2 on page 16 is not sufficient to allow such a graph to be constructed. In an evidence-based document, there is little scope for inclusion of unsubstantiated models. If the purpose of the graph in Box 2 is to convey an idea or a general trend which is known intuitively, but does not have hard evidence to support it, it would be much better to delete the scale on the vertical axis so that specific recovery rates are not implied. Alternatively, the graph could be removed altogether.

Furthermore, does the phrase "Patients with continuing symptoms of CFS" include people who have substantially improved but still have residual symptoms of CFS, no matter how minor; or does it refer only to people who still meet diagnostic criteria for CFS? In the absence of any references, it is difficult to interpret the graph.


* Doctor-patient relationship
On page 15 of the guidelines, under the heading 'Does the doctor-patient relationship affect the outcome of CFS?', it says:

"Simplistic notions offered by doctors, with unjustified medical labels such as 'chronic viral infection' or pseudomedical diagnoses such as 'hypoglycaemia', are inappropriate and unhelpful."

Readers of the guidelines should also be informed that unjustified labels such as 'malingering' and 'depression' are also inappropriate and unhelpful for people with CFS.



Treatment and Placebo Effect

* Extent of placebo effect
On page 17 of the guidelines it is stated that:

"At least 30%-50% of people with CFS typically demonstrate improvement in the non-specific (or 'placebo') treatment arm of controlled trials (Wilson et al. 1994a, Hickie et al. 1995b)."

There is no basis whatsoever for this statement, and it should be removed from the guidelines. The evidence is presented in Table 4 overleaf, where the controlled treatment trials listed in Box 4.1 on page 18 of the guidelines are again presented, but this time with their respective placebo response rates. Reference to the hydrocortisone trial of Straus et al. should be removed from Box 4.1 because it has not been published, and therefore has no place in the evidence-based guidelines. It is not included in Table 4.

It is also questionable whether the moclobemide trial of Wilson et al. 1994 should be referenced, since the only published information is an abstract, and it is not possible for readers to obtain full details of the trial. It is included in Table 4 overleaf nonetheless.

In the trials for which it was possible to calculate a placebo-response rate, those with the highest rates were Rowe 1997 (44%) and Straus et al. 1988a (42%). The total length of Rowe's study was nine months, including follow-up at six months after the end of treatment. The incidence of natural improvement in CFS over time - particularly in children - can be high, and this may have been a factor in the 44% of children who received placebo and who were significantly improved at the end of the study. Straus et al. also noted the potential impact of the natural history of the illness on the high placebo response found during their small 30 week trial.



============================================================

Table 4: Placebo Response Rate in Published Controlled Trials of Treatments for CFS

----------------------------------------

Immunological/Virological
Treatment: Intravenous immunoglobulin G
Study: Peterson et al. 1990
Sample Size: 28
Response Rate to Placebo or 'Non-Active' Treatment (%): 0*

Study: Lloyd et al. 1990
Sample Size: 49
Response Rate to Placebo or 'Non-Active' Treatment (%): 12

Study: Rowe 1997
Sample Size: 71
Response Rate to Placebo or 'Non-Active' Treatment (%): 44

Study: Vollmer-Conna et al. 1997
Sample Size: 99
Response Rate to Placebo or 'Non-Active' Treatment (%): Not stated but statistically significant
----------------------------------------
Treatment: Ampligen
Study: Strayer et al. 1994
Sample Size: 92
Response Rate to Placebo or 'Non-Active' Treatment (%): 0**
----------------------------------------
Treatment: Acyclovir
Study: Straus et al. 1988a
Sample Size: 24
Response Rate to Placebo or 'Non-Active' Treatment (%): 42
----------------------------------------
Treatment: Transfer factor
Study: Lloyd et al. 1993
Sample Size: 88
Response Rate to Placebo or 'Non-Active' Treatment (%): 33***
----------------------------------------
Treatment: Interferon-alpha
Study: See and Tilles 1996
Sample Size: 30
Response Rate to Placebo or 'Non-Active' Treatment (%): Paper not sighted



Behavioural
Treatment: Cognitive behaviour therapy
Study: Lloyd et al. 1993
Sample Size: 88
Response Rate to Placebo or 'Non-Active' Treatment (%): 33***

Study: Friedberg and Krupp 1994
Sample Size: 42
Response Rate to Placebo or 'Non-Active' Treatment (%): 0

Study: Sharpe et al. 1996
Sample Size: 60
Response Rate to Placebo or 'Non-Active' Treatment (%): 23

Study: Deale et al. 1997
Sample Size: 53
Response Rate to Placebo or 'Non-Active' Treatment (%): 19
----------------------------------------
Treatment: Graded exercise
Study: Fulcher and White 1997
Sample Size: 59
Response Rate to Placebo or 'Non-Active' Treatment (%): 27



CNS active agents
Treatment: Galanthamine hydrobromide
Study: Snorrason et al. 1996
Sample Size: 49
Response Rate to Placebo or 'Non-Active' Treatment (%): 4****
----------------------------------------
Treatment: L-carnitine
Study: Plioplys and Plioplys 1997
Sample Size: 30
Response Rate to Placebo or 'Non-Active' Treatment (%): No placebo arm
----------------------------------------
Treatment: Amantidine
Study: Plioplys and Plioplys 1997
Sample Size: 30
Response Rate to Placebo or 'Non-Active' Treatment (%): No placebo arm
----------------------------------------
Treatment: Moclobemide
Study: Wilson et al. 1994
Sample Size: 90
Response Rate to Placebo or 'Non-Active' Treatment (%): Abstract not sighted
----------------------------------------
Treatment: Fluoxetine
Study: Vercoulen et al. 1996
Sample Size: 96
Response Rate to Placebo or 'Non-Active' Treatment (%): 10
----------------------------------------
Treatment: Phenelzine
Study: Natelson et al. 1996
Sample Size: 18
Response Rate to Placebo or 'Non-Active' Treatment (%): 0



Metabolic/other
Treatment: Essential fatty acids
Study: Behan et al. 1990
Sample Size: 63
Response Rate to Placebo or 'Non-Active' Treatment (%): 17
----------------------------------------
Treatment: Magnesium sulphate
Study: Cox et al. 1991
Sample Size: 32
Response Rate to Placebo or 'Non-Active' Treatment (%): 18
----------------------------------------
Treatment: Liver extract + folic acid + vitamin B12
Study: Kaslow et al. 1989
Sample Size: 14
Response Rate to Placebo or 'Non-Active' Treatment (%): Not stated but ***** statistically significant
----------------------------------------
Treatment: Terfenadine
Study: Steinberg et al. 1996
Sample Size: 28
Response Rate to Placebo or 'Non-Active' Treatment (%): 0

----------------------------------------

* Some symptoms improved in some patients, but no clinically significant benefit was seen.

** Based on Karnofsky performance score. Minor improvement in other measures.

*** Stated that up to one third of people reported more than one standard deviation of improvement in physical and psychological status.

**** Placebo-controlled phase only lasted two weeks. Only one patient out of 24 (4%) receiving placebo improved more than 10% during this time.

***** Two week trial only (crossover design).

============================================================

Notwithstanding this it can be calculated from Table 4, for the studies for which figures are available, that the average placebo response rate is just 17%. Five studies had a zero percent placebo response rate. For the studies of Vollmer-Conna et al. 1997, and Kaslow et al. 1989, it is indicated that a statistically significant placebo response was found, but this response was not quantified in terms of the percentage of individuals who improved. If it is assumed that in each of these studies the rate of response to placebo was 50%, then the overall average placebo response rate becomes 20%.

For blinded controlled trials (ie. excluding trials of CBT and graded aerobic exercise therapy), the average placebo response rate is 15%; or 20% if the trials of Vollmer-Conna et al. and Kaslow et al. are included with an assumed 50% placebo response rate.

The studies of See and Tilles 1996, and Wilson et al. 1994, were not sighted and so are not included in this analysis. Even so, it can be seen that the statement in the guidelines that at least 30%-50% of people with CFS typically demonstrate improvement in the placebo arm of trials is unsupportable.


* Inadequate supporting references
Two references are given in the guidelines to support the above quote: Wilson et al. 1994a, and Hickie et al. 1995b. (The paper of Hickie et al. 1995b is titled 'Chronic fatigue syndrome: current perspectives on evaluation and management'). To justify comments about high placebo response rates in CFS, Hickie et al. 1995b in turn refer to two papers: Lloyd et al. 1993 (transfer factor trial), and Wilson et al. 1994a. Wilson's paper is a review, and presents no new data. To justify their own comments about high placebo response rates in CFS, Wilson et al. 1994a refer to two trials: Straus et al.1988a (acyclovir), and Kaslow et al. 1989 (liver extract plus vitamins). The study of Kaslow et al. is the smallest and shortest double-blind, placebo-controlled trial ever done with people with CFS - only 14 people participated in the trial, which lasted for just two weeks.

The paper of Hickie et al. 1995b was published at a time when eleven of the 23 trials listed in Box 4.1 had been published. Yet the authors directly or indirectly referred to only three of the eleven published trials. The comments in this paper about high placebo response rates in people with CFS were not valid in 1995, and they are even less valid today.


* Inconsistent ratings
Of the treatment trials listed in Box 4.1 in the guidelines, 15 out of 23 (65%) (excluding the hydrocortisone trial of Straus) are given a number 6 in the column headed 'Quality of study design and analysis'. The number 6 refers to the comment "Response rate to placebo therapy consistent with standard clinical care (ie. 15%-40%)". It is not stated where the figures for response rate to standard clinical care come from. Are they derived from trials with people with CFS, or are they the normal response rates to standard clinical care which occur across a range of medical illnesses?

Either way, if 65% of CFS treatment trials have placebo response rates between 15% and 40%, it is inconsistent with the claim that the typical placebo response rate is at least 30%-50%. However, of the trials that are given a number 6 rating, two had placebo response rates lower than 15%. These are the gammaglobulin studies of Peterson et al. 1990 (0%) and Lloyd et al. 1993 (12%). The number 6 should be removed from the 'Quality of study design and analysis' column for these two trials.


* Sample size
Sample size in Table 4 of this submission refers to the number of people who completed, or who partially completed, the trial and who were included by the authors in the analysis of results. Sample size in Box 4.1 in the draft guidelines refers to the number of people initially enrolled in the trial, regardless of whether or not they completed it, or whether or not they were included in the analysis of results. On either basis, the sample size for the study of Vollmer-Conna et al. 1997 in Box 4.1 should be 99 rather than 96.


* Further studies indicated
It is correctly noted in the first dot point in the text box on page 17 of the guidelines that no single pharmacological treatment has been shown to be effective for people with CFS. The absence of any effective treatment is the single greatest problem for people with CFS and their doctors. It is thus essential that controlled and blinded treatment studies are encouraged. Initial trials of four substances which have shown benefit for people with CFS need to be followed up with further trials. The four substances are: essential fatty acids; phenelzine; L-carnitine; and galanthamine.

It is correctly stated in Box 4.2 on page 19 of the guidelines that these drugs cannot currently be recommended for treatment use. There is limited knowledge about their efficacy and side effects when used by people with CFS. However, further studies are definitely indicated, and this should be stated in Box 4.2, as has been done for moclobemide and Ampligen.


* Speculation
It is stated on page 17 of the guidelines, under the heading 'What are the expectations of a treatment trial for CFS?', that:

"any claim that a particular treatment can cure most people with CFS is likely to be spurious, or the treatment will be acting via a non-specific mechanism."

This is speculation, and has no place in evidence-based guidelines. It is pre-empting the outcome of research into the pathophysiology of CFS, and is based on assumptions about the biological heterogeneity of people with CFS. There is little or no evidence to support these assumptions (see the sub-section on Heterogeneity below).

For example, in the essential fatty acid trial of Behan et al. 1990, there was a treatment response rate of 85%, and a placebo response rate of 15%. It is hard to see how a "non-specific mechanism" could account for the difference in response rates between the treatment and placebo groups, given that all patients took capsules that looked identical, and there was no regurgitation of fishy-tasting material. In addition, although most people with CFS who received the active treatment did report improvement, there is no good reason to deride the results as "spurious". The Working Group obviously thought that this study was of good enough design to be reported in the guidelines. So, although essential fatty acids did not 'cure' anyone with CFS, they did apparently help to improve the condition of a high percentage of people. This example is illustrative of the absurdity of sweeping statements like the one quoted above.





Pathophysiology

* Leading hypothesis?
On page 22 of the guidelines under the heading 'What are the major research findings in people with CFS?', it is noted that one of the five leading hypotheses about the pathophysiological basis of CFS is that the illness is the outcome of:

"a psychologically determined response to infection or other stimuli occurring in 'vulnerable' individuals (Imboden et al. 1961; Abbey 1993)."

There is no evidence offered in support of this statement in Boxes 5.1 to 5.4. While the study of Imboden et al. 1961 looked at convalescence in 26 people after influenza, this pathogen has not recently been associated with CFS (see Box 5.1, page 23). The follow-up period in this study was only three to six weeks after the initial illness(!), so it has little relevance to CFS. The studies of White et al. 1995 and Bruce-Jones et al. 1994, refute the above hypothesis in relation to the Epstein-Barr virus, which is a recognised viral trigger for CFS.

The paper of Abbey 1993 is a review, and offers no new evidence to support the hypothesis. Thus it is very difficult to see how the above quote is regarded as one of the "leading hypotheses" about the pathophysiological basis of CFS. After more than a decade of research into the illness, a leading hypothesis should have some good evidence to support it, and this one doesn't. The sentence quoted above should be removed from the guidelines.


* Retroviruses
It is stated on page 22, under the heading 'What are the gaps in our knowledge and priorities for future research' that:

"there is good evidence excluding several candidate mechanisms for the disorder, including retroviral infection..."

In the text box titled 'Phenomena associated with CFS' on page 22, it says:

"Retroviruses do not cause CFS (Level 1)".

And in Box 5.1 on page 23 under the heading 'Retroviruses' is the conclusion of:

"Strong evidence against a role for retroviruses in CFS."

It is frequently acknowledged in the literature on retroviruses in CFS that the findings of the studies do not preclude a role for unknown retroviruses. For example, Heneine et al. 1994 state that their very comprehensive study

"clearly does not exclude the involvement of other retroviruses in this population of CFS patients or of the assayed retroviruses in other such populations."

Therefore, the statements in the guidelines concerning retroviruses should refer to known retroviruses, and should not make any assumptions about as-yet unidentified retroviruses.


* Patient selection for research studies
It is also stated on page 22, under the heading 'What are the gaps in our knowledge and priorities for future research' that:

"Future studies must seek to identify potentially homogeneous patient groups, including subjects collected prospectively from defined infectious or other putative causes of CFS."

This is an important and valid approach to CFS research. However, in the paper of Fukuda et al. 1994 (page 956), common epidemiologic or laboratory features in people with CFS are regarded as optional subgrouping variables. There is no requirement for studies to be conducted with groups of individuals who had a similar onset to CFS, although researchers are free to pursue this approach if they wish. The wording in the guidelines should reflect this established consensus view.

It is valid to study groups of patients who meet diagnostic criteria for CFS, but who don't have a common identifiable cause for their illness. Valuable information and insights can be obtained from studying such cohorts. The pathophysiology of CFS in these groups may or may not be heterogeneous.

Observations about heterogeneity in CFS populations are based on patient symptomatology, and not on firm laboratory evidence (see Heterogeneity sub-section below). It may be that all people with CFS share some or all of the disease processes which contribute to the disorder. Just because the apparent triggering factor is different for individuals within the CFS population, it does not therefore follow that the ongoing disease process is different.


* Inconsistent levels of evidence
There are a couple of inconsistencies in the quality of evidence ratings for dot points in the text box titled 'Phenomena associated with CFS' on page 22, and their counterpart ratings in Box 5.3 on page 24.

For example, the fifth dot point in the text box on page 22 says:

"Neuroendocrine changes indicating hypothalamic-pituitary axis disturbance are common in people with CFS (Level III-4)..."

Yet in Box 5.3 under the heading 'Neuroendocrine function' it says:

"Impaired hypothalamic-pituitary-adrenal (HPA) axis activation has been demonstrated (Level III-2)."

There is clearly a discrepancy in the ratings given for what is essentially the same statement.

The sixth dot point in the text box on page 22 says:

"Sleep disturbance is very common in people with CFS (Level 1)..."

In Box 5.3 under the heading 'Sleep' it says:

"Disturbances of sleep maintenance (eg. frequent awakenings) are prevalent (Level III-2)."

Other evidence under the 'Sleep' heading is rated as Level III-3. So again there is a discrepancy between the ratings on page 22 and page 24.

These inconsistencies need to be reviewed and corrected.


* Pathogens not related to CFS
An extensive list of infectious agents has been investigated in people with CFS, and most have been found to have no association with the ongoing illness. It would be helpful for general practitioners to be given an idea of the range of infectious agents that have effectively been excluded. These are in addition to the pathogens listed in Box 5.1 on page 23 of the guidelines. In particular, the following reference lists more than forty microorganisms that have been screened for in people with CFS in a controlled study, and for which no association with CFS was found:

Mawle A C, Nisenbaum R, Dobbins J G, et al., 'Seroepidemiology of Chronic Fatigue Syndrome: A Case-Control Study', Clinical Infectious Diseases 1995; 21: 1386-1389.


* Other research studies
The guidelines would be strengthened with the inclusion of additional references relating to several areas of research. These references are discussed below. Their inclusion would be of interest to general practitioners and others who are using the guidelines as a resource. I recommend that Boxes 5.1-5.4 on pages 23 and 24 should be expanded as necessary to accommodate the additional studies, and that further boxes be added if it makes sense to do so.

Cardiac Function
Several papers have been published which examine cardiac function in people with CFS. These are not related to the neurally mediated hypotension studies which are mentioned in the guidelines. People with CFS often complain of chest pain or heart palpitations (as well as fatigue of course), so these particular studies have relevance to any discussion of the pathophysiology of CFS. The references are:

Montague T J, Marrie T J, Klassen G A et al., 'Cardiac Function at Rest and with Exercise in the Chronic Fatigue Syndrome', Chest 1989; 95: 779-784.

Lerner A M, Lawrie C, and Dworkin H S, 'Repetitively Negative Changing T Waves at 24-h Electrocardiographic Monitors in Patients with the Chronic Fatigue Syndrome', Chest 1993; 104: 1417-1421.

Lerner A M, Goldstein J, Chang C et al., 'Cardiac Involvement in Patients with Chronic Fatigue Syndrome as Documented with Holter and Biopsy Data in Birmingham, Michigan, 1991-1993', Infectious Diseases in Clinical Practice 1997; 6: 327-333.


Genetics
In Box 5.5 on page 25 of the draft guidelines, genetic make-up is cited as one of the risk factors for CFS. In the FAQs box on page 4, genetic influences are cited as being likely to contribute to the cause of CFS. However, there are no references given to support these statements. One published paper which does provide some evidence of genetic influences in CFS is:

Keller R H, Lane J L, Klimas N et al., 'Association Between HLA Class II Antigens and the Chronic Fatigue Immune Dysfunction Syndrome', Clinical Infectious Diseases 1994; 18 (Supplement 1): S154-S156.

This study should be referred to in the guidelines.


Biochemistry
Four studies looking at biochemical aspects of CFS are of general interest, and the guidelines would benefit from their inclusion:

Lieberman J and Bell D S, 'Serum Angiotensin-Converting Enzyme as a Marker for the Chronic Fatigue-Immune Dysfunction Syndrome: A Comparison to Serum Angiotensin-Converting Enzyme in Sarcoidosis', The American Journal of Medicine 1993; 95: 407-412.

Kuratsune H, Yamaguti K, Takahashi M et al., 'Acylcarnitine Deficiency in Chronic Fatigue Syndrome', Clinical Infectious Diseases 1994; 18 (Supplement 1): S62-S67.
Suhadolnik R I, Peterson D L, O'Brien K et al., 'Biochemical Evidence for a Novel Low Molecular Weight 2-5A-Dependent Rnase L in Chronic Fatigue Syndrome', Journal of Interferon and Cytokine Research 1997; 17: 377-385.

Burnet R B, Yeap B B, Chatterton B E et al., 'Chronic Fatigue Syndrome: Is Total Body Potassium Important?', Medical Journal of Australia 1996; 164: 384.

Neuroendocrine function
I believe that four additional neuroendocrine studies should be evaluated and referred to in the guidelines:

Bakheit A M O, Behan P O, Dinan T G et al., 'Possible Upregulation of Hypothalamic 5-Hydroxytryptamine Receptors in Patients with Postviral Fatigue Syndrome', British Medical Journal 1992; 304: 1010-1012.

Dinan T G, Majeed T, Lavelle E et al., 'Blunted Serotonin-Mediated Activation of the Hypothalamic-Pituitary-Adrenal Axis in Chronic Fatigue Syndrome', Psychoneuroendocrinology 1997; 22(4): 261-267.

Chaudhuri A, Majeed T, Dinan T et al., 'Chronic Fatigue Syndrome: A Disorder of Central Cholinergic Transmission', Journal of Chronic Fatigue Syndrome 1997; 3(1): 3-16.

Bennett A L, Mayes D M, Fagioli L R et al., 'Somatomedin C (Insulin-Like Growth Factor 1) Levels in Patients with Chronic Fatigue Syndrome', Journal of Psychiatric Research 1997; 31(1): 91-96.


Cytokines
A surprising omission from the list of cytokine studies presented in Box 5.2 on page 23 of the guidelines is:

Bennett A L, Chao C C, Hu S et al., 'Elevation of Bioactive Transforming Growth Factor-? in Serum from Patients with Chronic Fatigue Syndrome', Journal of Clinical Immunology 1997; 17(2): 160-166.

This was a large study which compared TGF-? serum levels in 93 people with CFS, 80 healthy controls, 46 people with major depression, 50 people with systemic lupus erythematosus, 41 people with relapsing/remitting multiple sclerosis and 16 people with chronic progressive multiple sclerosis. It was found that TGF-? levels were significantly elevated in people with CFS compared with the healthy controls and the disease comparison groups.

All studies that have examined the issue (including those of Chao et al. 1991, and Mawle et al. 1997) have found statistically significant elevations in levels of TGF-??in people with CFS. The level of evidence for increased concentrations of this cytokine in people with CFS is Level III-2, as opposed to Level III-4 for other cytokines. This is worth a mention in the guidelines.

Another cytokine study should also be referenced, since it is one of only three that have examined cytokine release in response to exercise in people with CFS:

Lloyd A, Gandevia S, Brockman A et al., 'Cytokine Production and Fatigue in Patients with Chronic Fatigue Syndrome and Healthy Control Subjects in Response to Exercise', Clinical Infectious Diseases 1994; 18 (Supplement 1): S142-S146.



Symptoms

Post-exertional malaise is one of the characteristic symptoms of CFS, as reported in Box 1 on page 1, and on page 5, of the guidelines. Malaise or post-exertional malaise have been reported by high percentages of people with CFS in studies involving large numbers of patients. For example, in a study of 281 people with chronic fatigue (of whom 91% met the original 1988 CDC criteria for CFS), 79% reported post-exertional malaise (Komaroff et al. 1996b). In another study of 217 people with postviral fatigue syndrome, 98% reported malaise (Miller et al. 1991).

Characteristic CFS symptoms are also listed on page 8 of the guidelines, under the heading 'How should a doctor evaluate fatigue?'. Post-exertional malaise has been omitted from this list and I request that it be included. Similarly, Box 5.5 on page 25 would benefit from the inclusion of post-exertional malaise as a symptom under either the immune pathway or perhaps the neuroendocrine pathway.

On page 9 of the guidelines, it is observed that:

"When adults present for medical assessment with fatigue states the most common alternative diagnosis to consider is major depression."

Komaroff et al. 1996b found that post-exertional malaise was much more commonly reported in people with CFS than in those with major depression (p<0.001), a finding that also applied to other flu-like symptoms in the 1994 CDC CFS diagnostic criteria set, including sore throat and headaches. Another smaller study also found that people with CFS were more likely to report recent flu-like symptoms than people with major depression (p<0.001). The reference for this latter study is: Lynch S P J, Seth R V and Main J, 'Monospot and VP1 Tests in Chronic Fatigue Syndrome and Major Depression', Journal of the Royal Society of Medicine 1992; 85: 537-540.

Thus it is important that at least post-exertional malaise, but preferably also sore throat and headaches, are listed among CFS symptoms on page 8 of the guidelines. I ask the Working Group to seriously consider whether the ability of flu-like symptoms to help discriminate between CFS and depression should be drawn to the attention of readers of the guidelines. Consistent with the evidence, I believe that in Box 2.5 on page 13, the symptom 'post-exertional malaise' should be included under the heading 'Chronic Fatigue Syndrome'.



Diet

On page 4 of the guidelines, in the text box on FAQs, under the heading 'Does a modified diet help?', it is stated that:

"There is no evidence to suggest that dietary treatment or 'megavitamin' therapy is effective in treating CFS."

At the Cambridge conference on CFS/ME, held on April 9-12, 1990, Dr Robert Loblay presented data from a study of food intolerance in people with CFS. Carefully designed, double-blinded challenges were undertaken after a strict elimination diet, and the study involved more than three hundred people with CFS suspected of having food intolerance. This work was reported in the following reference:

Loblay R H and Swain A R, 'The Role of Food Intolerance in Chronic Fatigue Syndrome', in The Clinical and Scientific Basis of Myalgic Encephalomyelitis/Chronic Fatigue Syndrome (Byron M Hyde, ed.), The Nightingale Research Foundation, Ottawa, 1992.

Dr Loblay's research found that the most common reactions were to salicylates, preservatives, glutamate and amines. Of 102 people with CFS who were followed up, 38% rated themselves as much better or completely well after their elimination diet at the time of initial testing. This paper estimates that food intolerance is a significant factor for 20-30% of people with CFS. Commenting on this study in The Medical Journal of Australia, Dr Andrew Lloyd noted:

"Elimination dietary therapy was conducted in a double-blind and placebo-controlled trial, in that the challenges (including placebo challenges) were presented to the patients in a random fashion generated by code; obviously the elimination diet itself could not be administered double-blinded. The results of this study showing that a minority of subjects do benefit therefore do partially control for a placebo effect from the treatment programme."

The reference for Dr Lloyds comment is:

Lloyd A R, 'Muscle Versus Brain: Chronic Fatigue Syndrome (reply)', The Medical Journal of Australia 1991; 154: 220.

In light of Dr Loblay's study, it is not justifiable to say in the guidelines that there is no evidence that dietary treatment is effective in treating CFS. There is evidence, and its rating is Level III-3. This is certainly stronger evidence than exists for some of the symptomatic treatments advocated on page 3 of the guidelines. I request that the wording in the text box on FAQs on page 4 be revised, and that some discussion of elimination diets be included in the text of the guidelines. Dr Loblay's study should be considered for inclusion in Box 4.1 on page 18.



Heterogeneity

It is stated in several places in the guidelines that CFS is a heterogeneous disorder. For example, on page 12:

"In fact, as the diagnosis of CFS currently identifies a heterogeneous group of people (Hickie et al. 1995), it is unlikely that any one diagnostic test will emerge."

and on page 17:

"Patient cohorts in CFS treatment trials are likely to be heterogeneous because of the relatively subjective and non-specific criteria used to make the diagnosis (Hickie et al. 1995a)."

and on page 22:

"The recognised heterogeneity within patient groups labelled as having CFS makes it highly likely that there are multiple contributing factors in the disorder."

The paper by Hickie et al. 1995 (titled 'Can the chronic fatigue syndrome be defined by distinct clinical features?'), which is used to support statements about patient heterogeneity, is contentious because it claims to be able to separate people with CFS into two different groups based on statistical differences, using a range of independent variables as measures. Closer examination of Table 2 on page 931 of the paper of Hickie et al. 1995, indicates that most of the variables are not independent, but are functions of illness severity. Hickie et al. correctly note that:

"Given the novel statistical approach used, however, the proposed solution and our interpretations require replication within independent samples."

To date, there has been no published replication of the study of Hickie et al. 1995. The evidence for patient symptom heterogeneity as presented in the guidelines is only Level III-3. The real issue is whether symptom heterogeneity reflects aetiological or pathophysiological heterogeneity. The statements in the guidelines imply that people with CFS are heterogeneous with respect to these two factors. However, at this stage there is no good published evidence to directly support this proposition. Clarification of this issue is unlikely to come until biological markers for CFS or sub-groups of CFS are identified.

The wording in the guidelines should emphasise that there is limited or preliminary evidence for symptomatic heterogeneity in populations of people with CFS, and that biological heterogeneity is an assumption based not on firm laboratory evidence, but simply on reports of patient symptomatology.



Support Groups

On page 21 of the draft guidelines, this sentence appears:

"Inevitably, members of CFS support groups tend to include those with the most prolonged illnesses (Sharpe et al. 1992)."

The paper of Sharpe et al. 1992 cannot be used to support this statement. Sharpe et al. found a correlation between functional impairment and membership of a patient organisation. Length of illness was not correlated with membership of a patient organisation. On page 151 of their paper, Sharpe et al. also noted that:

"the findings do not indicate the direction of cause underlying the associations".

Also on page 21 of the guidelines, it says that:

"Depending on the nature of the groups, some may serve to increase alienation from medical and government agencies and encourage forms of treatment that lack scientific evaluation."

I wish to point out that I am unaware of any instance in which any CFS Society has served to increase alienation from medical and government agencies. On the contrary, CFS Societies maintain lists of knowledgeable and sympathetic doctors so that Society members, and members of the general public who think they may have CFS, can be evaluated and treated in a fair and compassionate manner. Similarly, government agencies such as the Department of Social Security are important to people with CFS, and CFS Societies provide information about relevant government benefits and services to people who enquire. The above potentially damaging statement in the guidelines should be removed unless there is comprehensive evidence to support its inclusion.

As for encouraging forms of treatment that lack scientific evaluation, I also wish to emphasise that in its 171/2 year history, the CFS/ME Society of Victoria Inc. (of which I am a Life Member) has never advertised, promoted, endorsed or sold any form of treatment or therapy for CFS/ME.



Depression

On page 12 of the guidelines is the statement:

"Up to two-thirds of adults with CFS have either a prior, or concurrent, diagnosis of major depression, as do people with fibromyalgia and irritable bowel syndrome. By comparison, the lifetime rate of comparable depressive disorders in the general community is 15%-25%."

It would be more helpful for general practitioners and other readers if the figures for prior and concurrent depression in people with CFS were quoted separately. It would be useful for GPs to have an estimate of the likelihood of current depression in their CFS patients, but lumping prior depression in with concurrent depression simply confuses the issue and makes the incidence of depression in CFS appear higher than it actually is. Also, to be consistent with the presentation of data for community lifetime depression, an upper and lower range should be quoted for the incidence of prior and concurrent depression in people with CFS.

Readers should also be informed whether the CFS depression data come from community-based studies, or from highly selected tertiary referral samples. Readers were told this in relation to studies of the natural history of CFS (see page 15 of the guidelines), and it is only reasonable that this information is also included in the discussion on depression.



Nomenclature

On page 6 of the guidelines, nomenclature for CFS is discussed under the heading 'What other names are commonly used for CFS?'. There remains a need to address the term 'post-viral syndrome', since some patients are still being told by general practitioners that they have this condition. These patients are then confused about the relationship between post-viral syndrome and CFS. Since 'post-viral syndrome' has been abandoned as an alternative name for CFS or idiopathic chronic fatigue, this should be pointed out to general practitioners in the guidelines. This will then help to avoid any further confusion for people with either prolonged or idiopathic chronic fatigue, or CFS.



References

The numerous references are the foundation of the guidelines, and are a major resource for future readers. To maximise the validity and utility of the guidelines, it is desirable for the reference to be updated to March 1998, when the draft is revised. Some additional references have been suggested in this submission, but other highly relevant papers may now be available as well.



Consumer Input

A major effort was made by the Consumer Health Forum representative in compiling the 80 submissions originally received by the Working Group. A 'Compilation of Submissions' document, more than 200 pages long, was provided to members of the Working Group. Yet the draft guidelines contain very little direct information from the consumer submissions, apart from a few text boxes. Consumers were invited to comment on a range of issues, some of which received no coverage in the guidelines (eg. the needs of special groups such as children and adolescents).

Effective management of people with CFS requires empathy on the part of the treating medical practitioner. Empathy can be engendered by a better understanding of the experiences and the needs of people living with CFS. In the context of the evidence-based guidelines, this understanding can best be provided by including an Appendix (perhaps three or four pages long) which incorporates and summarises material from Craig Ellis' 'CFS Health Consumer Perspective'. This should be in addition to the consumer quotes already present in the draft guidelines.





5 Minor Areas for Improvement

The items presented in this section are listed in ascending page number order for ease of reference. Underlining is not used in this section to highlight explicit or implied recommendations for change since there is little discussion associated with each separate issue, and recommendations for change are therefore easy to identify.


Page 2, Understanding the illness
It is stated that:

"Both the doctor and the patient should avoid simplistic attributions of CFS to 'a virus', 'immune dysfunction', 'malingering', or 'mere depression'".

The words "mere depression" should be replaced with the word "depression". As pointed out elsewhere in the guidelines, CFS cannot be attributed to major depression, and laboratory findings in people with CFS differ from those in major depression (see Box 5.3, page 24). The presence of the word "mere" implies that perhaps CFS can be attributed to some other more complex form of depression, although no evidence for this is presented in the guidelines. In the absence of any such evidence, the word "mere" is inappropriate.


Page 3, Physical activity
It is stated that:

"In the early stages of the illness, many people with CFS make the mistake of putting off chores or social engagements until they feel better, then pushing themselves too hard on 'good days' to make up for lost time. The subsequent worsening of symptoms and delayed recovery can establish a cyclic pattern of illness and disability."

It should also be noted in the guidelines that some people with CFS try to 'push through' the illness in the early stages, and attempt to maintain a high level of activity in defiance of their symptoms. This exacerbates their CFS and can ultimately lead to a greater level of disability than would have otherwise occurred.


Page 4, FAQs
Under the heading 'What causes CFS?', the words "as well as genetic influences" should be replaced with the words "as well as genetic and environmental influences", to be consistent with the information in Box 5.5 on page 25.

Under the heading 'Is CFS a psychological disorder?', it needs to be stated clearly that CFS is not a primary psychological disorder.

Under the heading 'Is there a cure for CFS?', the words "there are a range of symptomatic and supportive treatments which are beneficial" should read "there are a range of symptomatic and supportive treatments which may be beneficial." This question should logically be placed above the question 'Will bed rest cure the illness?'.

Under the heading 'Will exercise cure the illness?', it should also be noted that excessive physical activity may also worsen symptoms in the medium term, particularly if the exercise provokes a major relapse.

In and under the heading 'Are people with CFS eligible for Sickness Benefits?', the words "sickness benefits" should be replaced with the correct words "sickness allowance". The other benefit which people with CFS may be able to receive is the disability support pension.


Page 5, Epidemiology box
It is stated in the second dot point in the text box titled 'Epidemiology' that:

"The prevalence of CFS in the community is 0.2%-0.5%...".

To be consistent with the data presented on pages 6 and 7, the prevalence figure should be "0.2%-0.7%".


Page 6, What other names are commonly used for CFS?
In the first paragraph under this heading, it is stated that the term 'chronic fatigue and immune dysfunction syndrome', or CFIDS, is inappropriate because it implies that the cause of CFS is immune deficiency. I wish to point out that immune dysfunction covers not only immune deficiency but also overactive immunity.


Page 6, Box 1.1
In Box 1.1, in the list of studies of the prevalence of fatigue in primary care, the study of Hickie 1996 should be entered above the study of Wessely 1997, to be consistent with the rest of the list which is in chronological order.


Page 9, How should a doctor evaluate fatigue?
The words "(see Boxes 3.1 and 3.3)" should read "(see Boxes 2.1 and 2.3)".


Page 11, Box 2.3
I suggest that in Box 2.3 titled 'Alternative causes of chronic fatigue', two more alternative causes are added. Under 'Sleep disorders', narcolepsy should be included so as to be consistent with Box 2.1. I also suggest that organophosphates be included under 'Occupational and environmental factors', to be consistent with Box 5.4.


Page 11, How should the context of the illness be assessed?
The following sentence appears under this heading:

"For example, it may be evident that an adolescent's 45-minute walk to school produces fatigue and other symptoms that last all day."

It is highly unlikely that anyone who can walk for 45 minutes will meet the CDC case definition for CFS. For people who do meet the CDC case definition, a 45 minute walk - if it could be completed - would be very likely to cause a significant exacerbation of symptoms for much more than the rest of the day. In fact, one of the symptoms listed in the CDC diagnostic criteria is post exertional malaise lasting more than 24 hours. It would be more suitable for a more realistic example to be used for someone with a mild form of CFS.

It is also noted that:

"At the severe end of the spectrum of CFS, people may be housebound and experience profound fatigue simply from the necessities of self-care such as showering or dressing."

It is important for general practitioners to be aware that in CFS the fatigue is often not the most distressing or disabling symptom. Other symptoms such as muscle pain, headaches or nausea can be worse at different times. I suggest that the above sentence should read "people may be housebound and experience profound fatigue and other symptoms from the necessities...".


Page 14, What are the benefits of a diagnosis of CFS?
The sentence:

"Making the diagnosis should mark the end of investigations to exclude alternative diagnoses."

should be expanded to remind general practitioners that a comprehensive fatigue assessment (which includes excluding alternative diagnoses) is required every twelve months, as per Box 2.2 on page 10 of the guidelines.


Page 15, What is the outcome of chronic fatigue states?
It is stated under this heading that:

"One death by suicide and two unrelated deaths occurred in 2075 people followed up in 19 published studies of the outcome of prolonged fatigue and CFS (Joyce et al. 1997)."

In fact, the words of Joyce et al. are:

"In some studies, it was not clear whether the vital status of the non-respondents was checked, hence the death rate could be higher. One of the known deaths was from an unrelated physical illness, another from an unspecified cause, and the other was by suicide."

The statement in the guidelines should be altered to correctly reflect the findings of Joyce et al.


Page 18, Box 4.1
In the column labelled 'Intervention', the words "Interferon alfa" should read "Interferon alpha" to be consistent with the title of the paper and with conventional spelling.


Page 19, Reference for moclobemide study
In the discussion concerning the moclobemide trial, reference is made to a paper by Hickie et al. 1998. No such paper has been published. The reference should be to the abstract of Wilson et al. 1994.

Page 19, Box 4.2
The asterisk at the end of the heading 'Recommendation for treatment use' does not have an associated footnote at the bottom of Box 4.2 (although it does appear in the Web version of the guidelines).

Page 22, What are the gaps in our knowledge and priorities for future research?
The word 'patholological', which appears near the bottom left hand corner, should be 'pathological'.

Page 24, Box 5.4
Under the heading 'Metabolic disturbance', the words "(McGregor et al. 1996a, 1996b)" are in a font which is too large compared with the other dot points in the Box. Immediately under this are the words "of CFS" in large bold type. These words should be part of the heading for Box 5.4, and they correctly come after the word "pathophysiology" in the heading.

Page 26, How were these clinical practice guidelines developed?
The words "see Clinical Practice Guidelines Box 1" should read "see Quality of Evidence Ratings Box on this page."

Page 32, Australian patient support groups
These groups should be listed in alphabetical order, or in order of size, but not in the haphazard manner which is evident on page 32.




6 Conclusion

The draft guidelines are comprehensive and attractive, and will be used widely once they are published in final form. There are, however, a number of areas in which the draft guidelines need improvement. These have been described in this submission. I believe that the changes required are extensive enough to warrant a second version of the draft being made available for public comment.

The Working Group should not be concerned if any changes cause the guidelines to be expanded by a few pages. There is a very good clinical overview at the front, and it doesn't matter if the document as a whole is a few pages longer than the first draft. It is important that readers are provided with up-to-date and accurate information in a comprehensible and succinct form.

Thank you for taking the time to read this submission.


Yours sincerely



Jim Oakley

Acknowledgment: I would like to thank Bernhard Liedtke for his assistance in obtaining some of the literature referred to herein.