Comment

WA State Department of Health EMS Comments

Washington State Department of Health supports the listing of the National Emergency Medical Services Information System (NEMSIS) standards for EMS data and only has one recommended change at this time. Washington State Department of Health recommends adding NEMSIS 3.5 as an emerging standard for emergency medical services data exchange, with implementation having began in Summer 2022. NEMSIS standards are an important collector of data for EMS in various contexts including public health, quality assurance and traffic safety.

WA State Department of Health EMS Comments

Washington State Department of Health supports the listing of the National Emergency Medical Services Information System (NEMSIS) standards for EMS data and only has one recommended change at this time. Washington State Department of Health recommends adding NEMSIS 3.5 as an emerging standard for emergency medical services data exchange as it likely could start being used in Spring of 2022. NEMSIS standards are an important collector of data for EMS in various contexts including public health, quality assurance and traffic safety.

NCPDP Comments

  1. When Emergency Medication is being administered, NDC and RxNorm could be used. Request ONC to add NDC and RxNorm as a value.
  2. Add the following:
Type-Standard Standard Implementation/Specification- National Drug Code (NDC) Standards Process Maturity – Final Implementation Maturity- Production Adoption Level – 5 Federally Required – Yes Cost – $ Test Tool Availability – N/A
  1. Add the following:
Type-Standard Standard Implementation/Specification- RxNorm Standards Process Maturity – Final Implementation Maturity- Production Adoption Level – 4 Federally Required – Yes Cost – Free Test Tool Availability – N/A

Preserving Clinical Context

General Comments: USCDI specifies lots of clinical data classes and data elements
  • Resolving to myriad de-coupled fragments
  • With vanishingly little focus on:
    • Clinical context and vital inter-relationships, e.g., between problems, diagnoses, complaints, symptoms, encounters, allergies, medications, vaccinations, assessments, clinical decisions, orders, results, diagnostic procedures, interventions, observations, treatments/therapies, referrals, consults, protocols, care plans and status...
    • Elements and context + purpose of capture:  e.g., blood pressure, its measurement (systolic, diastolic), its unit of measure (mm/Hg), its reason for capture, its context of capture (sampling site, sampling method, patient position, at rest/during/post exercise...
It is crucial to consider and determine/resolve how clinical content and context are bound together and preserved in USCDI.  The ultimate end user (often a clinician) must be able to readily discern context and inter-relationships – otherwise USCDI places an undue (and often unresolvable) burden on this user.  Only the source EHR/HIT system can structure clinical content and context properly.  Once data is stuffed into the USCDI framework and related exchange artifact (e.g., FHIR resources) this opportunity is forever lost.

The AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Health Care Data for Emergency Medical Services. CPT codes 99281 – 99285 identify patient evaluation, examination, and medical decision making for emergency department services. CPT code 99288 identifies the direction of emergency care to emergency medical services personnel by a physician or other qualified health care professional. CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

Regenstrief - Comment

We concur that the NEMSIS data set is an important collector of variables in the EMS context. In addition, we note that LOINC contains terms for observations and observation values for the complete NEMSIS data set (see panel 84428-2). Additionally, HL7 has developed the HL7 Version 3 Implementation Guide for CDA Release 2 - Level 3: Emergency Medical Services; Patient Care Report, Release 2 - US Realm, which uses the LOINC observation and observation values codes. http://www.hl7.org/implement/standards/product_brief.cfm?product_id=438

Further, it may also be worth mentioning that there is correlation between the NEMSIS (pre-hospital) data elements and the National Trauma Data Bank (NTDB) data dictionary, with the idea that the trauma registry could be “auto-populated” with the subset of relevant prehospital data. The National Trauma Data Standard data dictionary (2018 version) is also represented in LOINC (see panel 87825-6). HL7 has developed the HL7 CDA® R2 Implementation Guide: Trauma Registry Data Submission, Release 1 - US Realm, which uses LOINC. http://www.hl7.org/implement/standards/product_brief.cfm?product_id=355.

Last, the German Interdisciplinary Association of Intensive Care and Emergency Care Medicine defined a data set to enable efficient exchange from EMS pre-hospital services to receiving institutions. This complete data set of variables in the rescue service protocols are represented in LOINC (see panel 88677-0). This further supports the use of LOINC as a code system for use in this context.