To the Editor,

We write regarding the recent case report “Managing Chronic Migraine Using Toggle and Passive Care Techniques: A Case Report” published in the Journal of Contemporary Chiropractic.

The term “cervicogenic migraine” is not a recognized diagnosis in the International Classification of Headache Disorders, 3rd edition (ICHD-3). Cervicogenic headache (ICHD-3 11.2.1) and migraine are classified as distinct entities. If the headache originated from cervical structures—as the presentation and response to upper cervical care suggest—it would properly be classified as cervicogenic headache rather than migraine. The case report does not indicate that the diagnosis of migraine (or chronic migraine) was confirmed by a neurologist or headache specialist. Assigning a migraine diagnosis requires meeting specific ICHD-3 criteria and ruling out secondary causes and other primary headache disorders. Without documented neurological evaluation and differential diagnosis, the label of “chronic migraine” appears unsupported. For example, being “constant” in nature is not a diagnostic criterion for migraine headache.

The clinical improvement following toggle adjustments and passive care is consistent with a cervicogenic headache responding to targeted manual therapy. We suggest future case reports use precise, classification-based terminology to maintain diagnostic clarity and scientific rigor.

Thank you for your consideration.

Sincerely,

Steven Brown, DC, DIAMA, James Lehman, DC, MBA, DIANM

In Response:

We thank you for your comments regarding the diagnosis presented in our case study. The chiropractor’s diagnosis was based on the patient’s clinical presentation and reported symptoms at the time of each office visit. Given the overlapping features of migraine and cervicogenic headache, it was not possible to definitively distinguish between these diagnoses during the patient’s clinical encounters. Therefore, the diagnosis reflected the clinician’s professional judgement based on the available history, examination findings, and overall clinical presentation.

Sincerely,

Lisa Klaus, DC