A 2025 review published in Frontiers in Aging Neuroscience has brought renewed attention to a condition that’s becoming increasingly relevant in the context of personal injury claims: Functional Cognitive Disorder (FCD). For insurers and those involved in complex injury claims, the findings offer timely insights into a condition that is often misunderstood and frequently misdiagnosed.

What is Functional Cognitive Disorder?

FCD is a condition where individuals report persistent cognitive difficulties, such as memory lapses, trouble concentrating, or word-finding issues, without any identifiable neurological deficit. FCD cannot be identified on imagery or standard neuropsychological testing. 

Genuine FCD is thought to stem from psychological factors like anxiety, hypervigilance, or unhelpful beliefs about memory. The brain’s attention systems may become overly focused on normal lapses, which then reinforces the perception of cognitive decline.

Why this matters for insurers

From an insurance perspective, FCD presents a challenge. In the aftermath of an accident, it’s not uncommon for claimants to report ongoing cognitive issues. These may be attributed to a mild traumatic brain injury (mTBI) or post-concussion syndrome. However, in some cases, the symptoms may be better explained by FCD.

The risk here is twofold. First, there’s the potential for misdiagnosis, where FCD is mistaken for a more serious neurological condition. Second, without a clear understanding of FCD, insurers may find themselves facing inflated claims based on symptoms that do not align with objective medical evidence.

Spotting the signs

The review outlines several features that can help differentiate FCD from organic brain injuries:

• Inconsistency in test results: For example, a claimant may perform better on delayed recall than on immediate recall, something atypical in true memory disorders.
• Preserved daily functioning: Despite complaints, claimants often manage daily tasks without significant impairment.
• High levels of anxiety: Health-related anxiety is common and may drive the perception of cognitive problems.

These red flags can be particularly useful during claim assessments, especially when neuroimaging and cognitive testing do not support the severity of the reported symptoms.

How FCD differs from Functional Neurological Disorder (FND)

FCD is often grouped under the broader umbrella of functional disorders, but it’s important to distinguish it from Functional Neurological Disorder (FND), a condition insurers may already be familiar with.

• FND typically involves motor or sensory symptoms, such as limb weakness, tremors, gait disturbances, or non-epileptic seizures. These symptoms mimic neurological disease but are not caused by structural damage.
• FCD, by contrast, is focused specifically on cognitive symptoms such as memory problems, attention deficits, or difficulties with word-finding.

While both conditions are thought to arise from disruptions in brain function rather than brain structure, they affect different systems. FND tends to involve the body’s movement and sensory pathways, whereas FCD involves attention and memory.

Another key difference lies in presentation and assessment. FND often has observable signs during physical examination (e.g., Hoover’s sign), whereas FCD is typically identified through neuropsychological testing that reveals inconsistencies or inconsistent performance patterns.

Understanding this distinction is crucial when evaluating claims. A claimant presenting with cognitive complaints but no neurological findings may not have a mild brain injury, they may have FCD. Recognising this can help insurers direct cases toward appropriate assessment and treatment pathways, rather than assuming long-term impairment.

The importance of robust assessment

One of the key takeaways from the study is the need for thorough, multidisciplinary assessments. Neuropsychological testing remains a cornerstone, but it’s equally important to consider psychological factors and the broader clinical picture. The use of performance validity tests (PVTs) can also help assess the consistency and effort during cognitive testing.

For insurers, this underscores the value of medico-legal examinations conducted by clinicians familiar with FCD. These experts can help determine whether a claimant’s symptoms are more consistent with a functional presentation than organic brain injury.

Treatment and prognosis

The good news is that FCD is treatable. Interventions such as cognitive behavioural therapy (CBT), psychoeducation, and metacognitive training have shown promise in helping individuals manage their symptoms. Importantly, the condition is generally non-progressive, and many patients improve with the right support.

This has practical implications for claims management. Early identification of FCD and timely referral to appropriate psychological services can not only improve outcomes for claimants but also help contain the duration and cost of claims. It also supports a rehabilitation-focused approach, rather than one that assumes long-term disability.

Looking ahead

As awareness of FCD grows, it’s likely to become a more prominent feature in the assessment of cognitive injury claims. For insurers, this means staying informed and ensuring claims handlers and medical experts are equipped to recognise the condition.

Key steps might include:

• Training claims teams to understand the clinical features of FCD.
• Encouraging comprehensive assessments that include psychological as well as neurological evaluations.
• Challenging diagnoses of cognitive impairment that lack objective support, particularly in the context of low-impact injuries.
• Promoting early intervention to support recovery and reduce long-term claim exposure.

In summary, the review provides a valuable framework for understanding Functional Cognitive Disorder and its implications in the medico-legal arena. For insurers, it’s a reminder that not all cognitive complaints following injury are rooted in organic brain injury, and an evidence-based approach is essential to ensure fair and appropriate outcomes for all parties.