Comments on the ISA are accepted year-round, and changes are made to the web version of the ISA frequently throughout the year, based on comments and other changes to the health IT standards environment as ONC becomes aware of them. An annual Review and Comment period also occurs each summer-fall, when a majority of comments are received. See the process timeline below for more details.
Annual ISA Process Timeline
- January: Current Year Reference Edition is published, web version of ISA is available for ongoing review and comments.
- Winter/Spring/Summer: Changes may be made to the web-version of the ISA throughout the year, while the ISA Reference Edition remains static.
- Late Summer/Early Fall: Annual Review and Comment Period opens for sixty days - site changes are on hold so all reviewers are seeing the same content.
- Fall: ONC and HHS staff review comments received, make site updates and prepare the following year's Reference Edition for publication by early January.
How to Comment on the ISA
- An ISA site account is required in order to comment on the ISA.
- If you have an account already, click the "Login" button at the top right of the ISA.
- To create an account, click the "Login" button, then "Create new account" tab above the login window. Account approval is required, and is generally completed within 1 - 24 hours.
- Once you're authenticated to the ISA site, you can submit comments on most ISA pages - just scroll to the bottom of the relevant page, enter the text of your comment (or provide attachments, if needed) and submit. Your comment will be reviewed by ONC or other HHS subject matter experts, and changes will be considered for publication to the ISA.
- While comments by topic (posted to individual Interoperability Need pages) are preferred, and allow greater visibility to your comments by other industry stakeholders, consolidated comment letters are also accepted. You may provide these comments on general information pages, and ONC staff will triage them, and assign them to subject matter experts.
Comment
Submitted by hhaskell on 2021-02-05
Data Element: Patient's Goals
Patient's goals are likely to be robustly documented in the Nurses Care Plan, depending on the type of EMR. Would want to be able to capture current and active goals and those goals that have been completed or resolved.Submitted by hhaskell on 2021-02-05
Data Element: Health Concerns
This data element may have merit, especially if there are differences in the data element for Patient Goals and Encounter Diagnosis; but may be redundant...Also, maybe difficult to capture if it is not entered in a discrete field as part of the Nursing Care Plan or Physician Treatment PlanSubmitted by DrLucas on 2021-02-22
Support of the Gravity Project’s Submission to Include SDOH
To: The Honorable Donald Rucker, M.D. National Coordinator for Health Information Technology U.S. Department of Health and Human Services 330 C Street SW, 7th Floor Washington, D.C. 20201 Re: In Support of the Gravity Project’s Submission to Include Social Determinants of Health in the U.S. Core Data for Interoperability Dear National Coordinator Rucker: I write on behalf of the Gravity Project to ask for your quick help with a major opportunity—adding structured social determinants of health (SDOH) data to the U.S. Core Data for Interoperability (USCDI). The Gravity Project has done considerable groundwork and submitted the SDOH data elements to the Office of the National Coordinator (ONC), and ONC, in turn, has elevated the submission to the next step. The Gravity Project’s submissions would add critical domains such as food insecurity, housing instability, transportation insecurity, social isolation, and stress to the USCDI, integrated with core clinical activities such as assessments, diagnoses, interventions, and outcomes. As a healthcare provider for many years, I have seen firsthand the impact SDOH has on managing care and improving outcomes for patients. The challenges with meeting the needs of all seeking care have been exacerbated by COVID and have highlighted the inequities in the healthcare system. Addressing SDOH will be essential to ensure adequate care is received by all by including data elements to accurately and timely identify social needs and match those needs with community resources. The inclusion of SDOH as a new data class in USCDI, as proposed by the Gravity Project, will provide a consistent method to document and communicate these factors during a health care encounter. The Gravity Project has over 1,200 collaborators nationwide, representing diverse stakeholders who are committed to the goals of this project, standardize data collection and coding, and seamlessly exchanging SDOH data among all caregivers. Sincerely, Dr. Lisa Lucas National Director Healthcare Informatics SAS InstituteSubmitted by Emily Turek on 2021-08-19
American Association of Colleges of Nursing submits comments
Please see attached PDFSubmitted by College_of_Ame… on 2021-09-03
Comments from the College of American Pathologists
Please see attached.Submitted by toniki on 2021-09-14
Submitted by hhaskell on 2021-02-05
Data Element: Medications
Challenge to capturing medications is those that medications that don't make the typical clinically documented med list such as herbal and at times OTC medications. These often are documented narratively in nurses or physician notes dependent on the type of EMR or documentation system.