The ICD Crisis: How the U.S. Withdrawal from WHO Threatens Your Practice’s Ability to Get Paid

On January 22, 2026, something happened that most therapists barely noticed, yet it threatens the fundamental infrastructure of how we get paid for our work. The United States formally completed its withdrawal from the World Health Organization (WHO), ending a 78-year relationship that began with the U.S. as a founding member of the post-World War II international health order. This event, triggered by Executive Order 14155 signed by President Donald Trump on January 20, 2025, is not merely a diplomatic spat or a budgetary decision. It represents a fundamental dismantling of the collaborative infrastructure that underpins modern medicine, biosecurity, and critically for those of us in private practice, health data standardization.

The administration’s stated rationale centers on allegations of systemic mismanagement, particularly regarding the WHO’s response to the COVID-19 pandemic, and a perceived lack of independence from political influence by rival superpowers. Proponents argue this restores sovereignty and allows the nation to redirect resources toward bilateral health engagements that more directly serve American interests. However, the consequences of this decision extend far beyond the diplomatic corridors of Geneva. They penetrate deep into the operational machinery of every hospital, psychotherapy practice, and medical research facility in the United States.

At the heart of this disruption lies the International Classification of Diseases (ICD), the proprietary coding system owned by the WHO that serves as the “operating system” for global healthcare. The question of whether these codes might become “inaccessible” to the United States is technically complex, touching on intellectual property law, international treaties, and the intricate bureaucracy of medical billing. By withdrawing from the WHO, the United States has effectively ceded control over the future of this system (a system it largely helped build) to other nations, while locking its domestic healthcare infrastructure into a rapidly obsolescing standard.

This article provides an exhaustive analysis of the withdrawal’s implications, dissecting the legal mechanics of the exit, the fate of U.S. financial obligations, the technical divergence of health data standards, and the granular operational impacts on American healthcare providers, especially those of us in mental health practice. I’ll explore how a geopolitical decision made in the White House creates a cascade of consequences that threatens to isolate U.S. medical science and disrupt the revenue cycles of safety-net hospitals and private practitioners alike.

The Mechanism and Timeline of Withdrawal

The withdrawal was set in motion on the first day of President Trump’s second term. Executive Order 14155, titled “Fulfilling a Promise to America,” formally initiated the one-year notice period required by the 1948 Joint Resolution that authorized U.S. participation in the WHO. This executive action was accompanied by a directive to terminate all U.S. government funding to the organization, recall U.S. personnel and contractors from WHO headquarters, and suspend participation in all technical working groups.

The timeline reveals a calculated dismantling: On January 20, 2025, notification of intent to withdraw was submitted to the UN Secretary-General, triggering the one-year countdown. Throughout the 2025 fiscal year, the U.S. government halted all assessed contributions (dues) and voluntary funding, accumulating significant arrears. Then on January 22, 2026, the Department of State and the Department of Health and Human Services (HHS) issued a joint statement declaring the withdrawal complete. Post-January 2026, the U.S. entered a phase of “non-member” status, though the legality of this status is contested due to unmet financial obligations.

This timeline reveals a calculated dismantling of ties, yet it leaves behind a debris field of unresolved legal and financial commitments that complicate the “clean break” narrative presented by the administration.

The Legal Quagmire: Arrears and the “Zombie Membership”

The premise of the U.S. withdrawal relies on the assumption that a sovereign nation may exit an international treaty at will. While generally true, the specific terms of the United States’ entry into the WHO in 1948 created a unique complication that now haunts its exit. Unlike many other nations, the United States did not join the WHO solely through executive treaty power. Participation was authorized by Congress via a Joint Resolution (62 Stat. 441), which contained a specific reservation regarding withdrawal. Section 4 of this resolution stipulates that the United States reserves the right to withdraw from the organization provided that two specific conditions are met: a one-year notice is given to the WHO (which was satisfied on January 20, 2025), and the United States must pay its financial obligations in full for the current fiscal year.

Legal scholars, including Lawrence Gostin of Georgetown University, argue in a peer-reviewed analysis that because the administration explicitly halted payments during the notice period, the second condition of the Joint Resolution has not been met. This creates a domestic constitutional crisis: the Executive Branch has executed a withdrawal that violates the legislative terms set by Congress for that very withdrawal.

As of the withdrawal date in January 2026, the United States is in significant financial arrears. The WHO financial reports indicate that the U.S. failed to pay its assessed contributions for the 2024-2025 biennium. The total outstanding debt is estimated to be between $260 million and $280 million. The State Department has adopted a hardline stance, declaring that the U.S. “will not be making any payments” to the WHO before withdrawal. The rationale provided is compensatory: the administration argues that the economic damage inflicted on the U.S. economy by the WHO’s alleged failures during the COVID-19 pandemic far exceeds the monetary value of the dues.

This creates what international lawyers describe as a “messy divorce” or “Zombie Membership.” From the WHO’s perspective, the WHO Constitution does not contain a withdrawal clause. The only mechanism for exit is the one the U.S. negotiated for itself in 1948. If the U.S. fails to meet the conditions of that mechanism (payment), the WHO may technically consider the U.S. still a member, albeit one in default. Under Article 7 of the WHO Constitution, a member in arrears can have its voting privileges suspended. While the U.S. has voluntarily vacated its seat, this legal distinction matters for future re-entry. If a future administration seeks to rejoin, the “unpaid bill” will remain a prerequisite for the restoration of voting rights, effectively putting a $260 million price tag on any future diplomatic pivot.

Let me break down the financial implications: The annual assessed contribution of approximately $111 million has been terminated, creating immediate savings for the U.S. budget but revenue loss for WHO. Voluntary contributions of $500 to $800 million have been terminated, creating loss of funding for polio, HIV/AIDS, and emergency response programs globally. Outstanding arrears of $260 to $280 million remain unpaid and disputed, creating a legal barrier to “clean” withdrawal and potential litigation in international courts. Future liability is zero as the U.S. assumes no future liability but loses all claim to WHO assets and intellectual property.

Understanding the ICD System: What We’re Really Talking About

To understand the threat to your practice, you first need to understand the International Classification of Diseases (ICD) not as a mere list of medical terms, but as a proprietary piece of intellectual property owned, maintained, and licensed by the World Health Organization. The premise that these codes might become “inaccessible” is grounded in the reality of copyright law and the severing of the licensing agreements that bind the U.S. to the global system.

The ICD is the bedrock of the global health information infrastructure. It provides a common language that translates a clinician’s diagnosis (e.g., “Major Depressive Disorder”) into an alphanumeric code (e.g., F33.1). This code allows data to be aggregated for mortality statistics, billing reimbursement, and epidemiological surveillance. The WHO explicitly holds the copyright to the ICD-10 and the new ICD-11. Unlike ICD-9, which is largely in the public domain, the modern versions are protected intellectual property. The WHO typically grants royalty-free licenses to Member States to use, translate, and modify the ICD for “government purposes” (e.g., national vital statistics and public insurance programs). Commercial users (e.g., software vendors) must often pay royalties.

The United States does not use the standard international version of ICD-10. Instead, it uses a heavily modified version known as ICD-10-CM (Clinical Modification). This version was developed by the National Center for Health Statistics (NCHS) under an authorization agreement with the WHO. Why modify? The U.S. healthcare system requires significantly more granularity for reimbursement than the international version provides. While the base ICD-10 has approximately 14,000 codes, the U.S. ICD-10-CM contains nearly 72,000 codes. The critical dependency here is that the “CM” version is a derivative work. Its underlying structure (the chapters, the categories, the base codes) belongs to the WHO. The U.S. adds the detail (the “branches”), but the WHO owns the “trunk.”

Deconstructing the “Inaccessibility” Premise

The concern that codes will become “inaccessible” must be parsed into two distinct risks: Legal Inaccessibility and Semantic Inaccessibility.

Legal Inaccessibility: Can the WHO “Turn Off” the Codes?

It is highly unlikely that the WHO could force the U.S. to stop using the current ICD-10-CM. The ICD-10-CM code set is embedded in U.S. federal regulation (HIPAA Administrative Simplification Standards). It is the law of the land for all “covered entities” (insurers, hospitals, clearinghouses). While the U.S. is withdrawing, legal precedents suggest that the authorization to create the derivative work (ICD-10-CM) was granted years ago. The WHO cannot easily revoke rights to a system already deployed across the entire U.S. economy. Even as a non-member, the U.S. government (CMS and CDC) can claim that maintaining the health of its citizenry is a sovereign function that supersedes WHO copyright claims, particularly for the existing version.

Semantic Inaccessibility: The Real Threat

The true danger is Semantic Inaccessibility, the inability to access new codes and the meaning behind them. The WHO creates new codes for emerging diseases (e.g., a new strain of Monkeypox or a novel coronavirus). Previously, the U.S. had a seat at the table (the WHO-FIC Network) to receive these codes and their definitions before they were published. Post-withdrawal, the U.S. NCHS is cut off from the pre-publication data stream. When a new disease emerges, the WHO will assign it an ICD-11 code. The U.S., using ICD-10-CM, will have no equivalent code. The NCHS will have to unilaterally invent a code.

The result? The U.S. code and the Global code will no longer match. The data becomes inaccessible to international researchers because “U.S. Pneumonia” no longer means the same thing as “Global Pneumonia.” The U.S. becomes a data island.

The Irony: Abandoning Our Own Creation

The tragedy of the withdrawal is compounded by the fact that the modern ICD system is, in many ways, an American invention. By leaving the WHO, the United States is effectively abandoning a structure it spent decades optimizing for its own benefit. Historically, the ICD was purely for mortality (death certificates). It was the United States, in the 1970s, that pushed for the creation of “Clinical Modifications” to make the system useful for morbidity (hospital billing). ICD-9-CM, developed by the U.S. in 1977, introduced the concept of procedure coding (Volume 3) and expanded diagnosis coding to support the burgeoning U.S. health insurance industry. The U.S. model of using detailed coding for reimbursement became the global gold standard for activity-based funding. The U.S. essentially trained the world to view health data as a financial instrument.

Until January 2026, the National Center for Health Statistics (NCHS) housed the WHO Collaborating Center for the Family of International Classifications for North America (USACC). This center was the operational bridge between U.S. clinical needs and global standards. It ensured that when the WHO revised the ICD, it did so in a way that was compatible with U.S. computing systems and clinical practices. With the recall of U.S. personnel and the termination of this designation, the U.S. loses its “brain trust” connection. The NCHS staff no longer have the official standing to propose changes to the WHO. They are now outsiders looking in.

Ceding the Field to Geopolitical Rivals

The vacuum left by the U.S. withdrawal allows other nations to reshape the ICD to their advantage. The most prominent example is the rise of Traditional Chinese Medicine (TCM). In ICD-11, the WHO included a new chapter on Traditional Medicine (Chapter 26), heavily influenced by lobbying from China. This chapter legitimizes diagnoses based on concepts like “Qi stagnation” or “Meridian blockages” alongside Western evidence-based medicine. Historically, U.S. delegates (and other Western nations) pushed back against integrating non-evidence-based concepts into the core classification, arguing it diluted scientific rigor.

By withdrawing, the U.S. has ceded the ability to police this boundary. China is now the dominant voice in the WHO-FIC network. As ICD-11 spreads, TCM codes will become standard in global insurance data, potentially forcing U.S. insurers operating internationally to reimburse for these treatments, while U.S. science loses the ability to frame the global medical narrative.

The Hospital Crisis: Revenue Cycle Collapse

For U.S. hospitals, the withdrawal is not an abstract diplomatic dispute; it is an operational crisis that threatens the Revenue Cycle Management (RCM) infrastructure. The entire financial circulatory system of U.S. healthcare (from admission to discharge to payment) runs on ICD-10-CM codes.

Hospitals are paid by Medicare and private insurers based on Diagnosis-Related Groups (DRGs). A patient’s DRG is determined by their ICD-10-CM diagnosis and procedure codes. The DRG system requires annual updates to account for new diseases and new medical technologies. These updates rely on the NCHS and CMS “Cooperating Parties” to curate new codes. Without WHO input, the NCHS must maintain ICD-10-CM in isolation. As medical science advances globally (as defined by ICD-11), the U.S. system will lag.

Here’s a concrete example: A new immunotherapy treatment requires a specific diagnosis code to trigger payment. The rest of the world uses the ICD-11 code. The U.S. has no code. Hospitals must use a “Not Elsewhere Classified” (NEC) code. NEC codes trigger automatic audit flags. Claims are denied or delayed. Hospital cash flow is disrupted as they fight for reimbursement for modern treatments using obsolete codes.

Major Electronic Health Record (EHR) vendors like Epic, Cerner (Oracle), and Meditech operate globally. They are currently investing billions to upgrade their platforms to ICD-11 for clients in Europe, Canada, and Asia. If the U.S. remains on ICD-10-CM while the world moves on, the U.S. market becomes a “legacy” product line. Vendors will not absorb the cost of maintaining two separate codebases (the modern ICD-11 for the world and the archaic ICD-10 for the U.S.). These costs will be passed to U.S. hospitals in the form of increased licensing fees and “customization” charges. The American Hospital Association (AHA) has already warned that the transition costs (or the costs of not transitioning) could run into the millions for large systems.

U.S. academic medical centers participate in global clinical trials to test new drugs. Pharmaceutical companies require data to be submitted in a standardized format, increasingly in ICD-11. A U.S. hospital enrolling a patient in a global cancer trial will have to code the patient twice: ICD-10-CM for the insurance bill (to get paid) and ICD-11 for the clinical trial registry (to contribute data). This “crosswalking” is prone to error. Mapping tables (GEMs) are imperfect. Semantic errors will creep in, potentially invalidating the U.S. arm of global studies or causing U.S. data to be excluded from meta-analyses due to incompatibility.

The Mental Health Crisis: When Your Diagnosis Doesn’t Have a Code

The impact on mental health professionals is particularly acute due to the unique “dual-key” nature of psychiatric diagnosis in the United States. We diagnose using the Diagnostic and Statistical Manual of Mental Disorders (DSM), but we bill using ICD codes. The withdrawal threatens to break the link between these two systems.

The American Psychiatric Association (APA) publishes the DSM-5-TR (Text Revision). This manual does not contain its own billing codes; it borrows codes from ICD-10-CM. The problem is that the global mental health community has moved to ICD-11, which introduces radically different concepts for mental health. The U.S., stuck on ICD-10-CM, cannot access these new concepts for billing.

Complex PTSD (CPTSD)

ICD-11 formally recognizes Complex PTSD (resulting from chronic, repeated trauma) as distinct from standard PTSD. This is the clinical reality for many of us: we treat CPTSD daily. Yet the billing reality is stark. There is no ICD-10-CM code for CPTSD. Therapists must code it as “PTSD, Unspecified” (F43.10). This fails to capture the severity of the condition and can lead to insurers authorizing fewer sessions than the patient actually needs. You know your client needs 50 sessions of intensive trauma work for childhood developmental trauma, but the insurance company sees “PTSD” and authorizes 12 sessions because they’re thinking single-incident trauma.

Prolonged Grief Disorder

The DSM-5-TR introduced Prolonged Grief Disorder to align with upcoming ICD-11 changes. Because the U.S. NCHS is no longer harmonizing with the WHO, the specific ICD-10-CM code for this disorder may not be updated to reflect the nuances of the global definition. U.S. therapists risk having claims denied because the “Grief” diagnosis is often flagged by insurers as a non-medical “life transition” issue unless it is coded with extreme precision. I’ve had colleagues tell me they can’t get bereavement cases covered at all unless they can justify it as complicated by depression or anxiety, forcing them into diagnostic contortions.

Gaming Disorder

ICD-11 includes Gaming Disorder. The DSM-5-TR lists it only as a “condition for further study.” The consequence? U.S. therapists cannot bill for treating a child with severe video game addiction. They are forced to engage in “diagnostic upcoding,” diagnosing the child with “Major Depressive Disorder” or “ADHD” just to get the insurance company to pay for the therapy. This distorts the patient’s permanent medical record and creates liability for the therapist. You’re treating gaming addiction, but the permanent record says depression because that’s the only code that will get paid.

The “Abuse vs. Dependence” Semantic Trap

One of the most frustrating aspects of the U.S. stagnation is the language of addiction. Modern science (DSM-5 and ICD-11) views addiction as a spectrum (“Use Disorder” with specifiers of Mild, Moderate, Severe). US billing (ICD-10-CM) still uses the antiquated 1990s language of “Abuse” versus “Dependence.” Every day, U.S. psychotherapists must mentally translate a clinical diagnosis of “Alcohol Use Disorder, Moderate” into the billing code for “Alcohol Dependence.”

This is not just a semantic annoyance; it is a stigmatizing legal label that follows the patient in their insurance history. When a patient applies for life insurance or disability insurance five years later, what shows up? “Alcohol Dependence.” Not the more nuanced, less stigmatizing “Alcohol Use Disorder, Moderate, In Sustained Remission.” The U.S. withdrawal ensures that this obsolete, stigmatizing language will remain the legal standard in American healthcare for the foreseeable future.

The Private Practice Revenue Nightmare

Psychotherapy practices, often small businesses, operate on thin margins. The “Superbill” is our lifeblood. Many U.S. therapists now treat patients globally via telehealth. If a U.S. therapist sends an ICD-10-CM coded superbill to a patient in Europe (where the insurer uses ICD-11), the claim will likely be rejected. The U.S. provider loses the ability to interface with the global insurance market. As someone who consults internationally and has colleagues practicing across borders, this is already becoming a real problem.

As the DSM and ICD-10-CM drift further apart without the WHO harmonization process, the discrepancy between the clinical notes (using DSM language) and the billing claim (using ICD-10 language) will widen. Insurers use algorithms to spot these discrepancies and trigger clawbacks (demands for repayment). I write in my notes that someone has “Major Depressive Disorder, Recurrent Episode, Moderate Severity, with anxious distress.” But when I bill, the ICD-10-CM code might not perfectly capture that combination of specifiers. The algorithm flags it. Six months later, I get a letter demanding I return $1,500 because my documentation doesn’t “support” the code I billed. This is already happening with the current system; it will only get worse as the gap widens.

Beyond Billing: The Broader Consequences

Beyond the direct impacts on hospitals and therapists, the withdrawal creates a series of second-order effects that will ripple through the entire healthcare system.

The Biosecurity Blindspot

The WHO coordinates the Global Influenza Surveillance and Response System (GISRS). This network collects flu samples from 100+ countries to decide the composition of the annual flu vaccine. The U.S. is no longer a member. It has lost its automatic right to access this data and the viral samples. The CDC must now negotiate bilateral agreements with individual countries to get flu samples. This is slow and patchy. If the U.S. selects a flu vaccine strain based on incomplete data and misses the dominant global strain, the result could be a catastrophic flu season with thousands of excess deaths and billions in economic loss. This “penny-wise” saving on WHO dues could cost the U.S. economy profoundly.

The Disruption of Interoperability

The Office of the National Coordinator for Health IT (ONC) has spent decades trying to make U.S. health data “interoperable” (able to be shared easily). Withdrawal is a move toward isolation. By freezing on ICD-10-CM while the world moves to ICD-11 (which supports “semantic interoperability” and linking with SNOMED CT), the U.S. is effectively unplugging its digital health network from the rest of the world. U.S. health tech companies (Apple Health, Fitbit/Google, etc.) that rely on global standards for their algorithms will have to build “U.S.-specific” versions of their products, reducing innovation and slowing the deployment of AI in healthcare.

The Research “Brain Drain”

The NCHS and CDC relied on the constant flow of ideas from the WHO-FIC network to keep their staff sharp. “Recalling” U.S. experts from Geneva cuts them off from the global debate. The next generation of U.S. nosologists (classification experts) will be trained on an obsolete system. The intellectual capital of the U.S. public health service will degrade over time, leading to lower quality data and poorer health policy decisions.

What This Means for Your Practice Tomorrow

Let me be concrete about what this means for those of us in private practice over the next few years:

Immediate Term (2026-2027): Nothing dramatic changes. You continue using ICD-10-CM codes. Your superbills still get processed. But watch for increased claim denials on newer diagnoses that don’t fit neatly into old categories. Start documenting more thoroughly to justify any code that might be questioned.

Medium Term (2027-2029): The gap widens. New presentations (Long COVID psychiatric sequelae, emerging substance use patterns, novel trauma presentations) lack appropriate codes. You’ll increasingly face the choice between diagnostic accuracy and billing accuracy. Your EHR vendor will start charging “legacy support fees” to maintain the U.S.-specific version while they upgrade the rest of the world to ICD-11.

Long Term (2030+): The U.S. system becomes genuinely archaic. Younger clinicians trained on DSM concepts will struggle to translate into billing codes that reflect 1990s psychiatric nosology. International collaboration becomes difficult. Research using U.S. data gets excluded from global meta-analyses because the coding is incompatible. The intellectual isolation becomes real.

The Cost of Medical Isolationism

The United States’ withdrawal from the World Health Organization is a decision with a “long tail” of consequences. While the immediate “inaccessibility” of codes is overstated (the codes will remain on the books and in the software), the utility of those codes will decay rapidly.

By severing the link to the ICD-11 infrastructure, the United States has chosen to lock its hospitals, therapists, and researchers into a “time capsule” of 1990s medical classification. The costs of this decision will be borne by hospitals forced to pay for legacy software support and fight increasing claim denials, therapists forced to use stigmatizing and inaccurate codes that do not match their clinical reality, and patients who may receive care based on outdated data or whose complex conditions (like Long COVID or CPTSD) may go unrecognized by a system that lacks the codes to name them.

Strategically, the U.S. has ceded the high ground. The “empty chair” at the WHO is not truly empty; it is now occupied by the United States’ geopolitical rivals, who are rewriting the dictionary of global health in their own image. The U.S. has saved $260 million in dues, but it has potentially cost itself the leadership of the global life sciences economy.

Let me summarize the key impacts by sector:

For government (HHS/CDC), the primary impact is loss of global surveillance data for flu and pandemics, with the secondary consequence of degradation of biosecurity and vaccine efficacy.

For hospitals and their revenue cycle management, the primary impact is divergence of billing codes from clinical reality, with secondary consequences of increased claim denials and high IT “legacy” costs.

For psychotherapy, the primary impact is inability to bill for modern diagnoses like CPTSD, with secondary consequences of ethical conflict between diagnosis and billing, plus increased audit risks.

For research and pharmaceutical companies, the primary impact is data incompatibility with global trials, with secondary consequences of increased cost of drug development and exclusion from meta-analyses.

Geopolitically, the primary impact is loss of influence over global standards (allowing the rise of TCM and other systems), with the secondary consequence that rival nations (China) shape future health norms.

A Personal Reflection

As someone who has spent years integrating neuroscience, evidence-based practice, and depth psychology in my clinical work, I find this situation particularly troubling. We are watching a geopolitical decision create a scientific and clinical crisis that will take decades to resolve. The work we do as therapists requires precision, nuance, and the ability to name what we see. When the naming system itself becomes corrupted by political expediency, when our diagnostic language diverges from our clinical reality, we are not just losing administrative efficiency. We are losing the ability to accurately represent the suffering of our clients to the systems that control access to care.

This is not abstract. This is about whether the teenager you’re treating for gaming addiction can get coverage. This is about whether the trauma survivor in your office with Complex PTSD can access the intensive treatment they need. This is about whether your notes, written with clinical accuracy, will be rejected by an algorithm six months from now because the code you used doesn’t “match” what the insurance company’s 1990s-based system expects.

We built this system. We created the clinical modifications that made the ICD useful for the kind of precise, reimbursable mental health care that allows people to access treatment. And now, through a combination of political posturing and genuine policy disagreement, we are watching that system be frozen in time while the rest of the world moves forward.

The question for each of us is: How do we practice ethically in a system that is becoming increasingly divorced from clinical reality? How do we document accurately while also ensuring our clients can get paid? How do we maintain scientific rigor when the very coding system we’re required to use is becoming obsolete?

These are not theoretical questions. They are the daily ethical dilemmas that will define clinical practice in the United States for the next decade. We need to be aware of what’s happening, document meticulously, advocate for our clients, and prepare for a healthcare landscape that is increasingly isolated from the global standard of care.

The U.S. has chosen medical isolationism. Those of us in the trenches of clinical practice will bear the cost.

Key Authoritative Sources Referenced:

• U.S. Department of Health and Human Services: Fact Sheet on U.S. Withdrawal from WHO
• Centers for Disease Control and Prevention: ICD-10-CM Classification
• Centers for Medicare & Medicaid Services: ICD-10 Codes and Billing
• World Health Organization: International Classification of Diseases
• American Psychiatric Association: DSM-5-TR Resources
• National Institutes of Health/PMC: Legal Analysis of WHO Withdrawal
• American Hospital Association: ICD-11 Implementation Concerns
• The BMJ: Analysis of U.S. WHO Withdrawal Legal Questions

This article is for informational purposes and represents analysis of publicly available information as of January 2026. Consult with billing specialists, legal counsel, and professional organizations for guidance specific to your practice.