Representing Immunizations

The American Immunization Registry Association (AIRA) appreciates the structure and organization of this section. We do have one formatting recommendation; both “Immunization Information System (IIS)” and “State Registry” are used above and throughout the ISA to refer to IIS. We prefer the term Immunization Information System as it is more inclusive of the broad functionality encompassed within these systems. Additionally, some IIS are operated at the city level, rather than the state level, so state registry would be better referred to as jurisdictional IIS.

AIRA Comments - Administered and Historical Immunizations

The "Representing Immunizations - Historical" page is very similar to the administered page. It includes the same 5 code sets and mostly the same considerations (in blue). AIRA proposes these be consolidated into a single page and deal with the nuanced differences in the blue Considerations section rather than retain and maintain two nearly identical pages.

NCPDP Comments

RxNorm – is not utilized for reporting of previous dispensing.

NCPDP Comment

NCPDP supports ONC’s recommendations.

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, history and physical findings, allergies, medications, vaccinations, assessments, goals/objectives, 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, determine and 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 American Medical…

    The American Medical Association requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Immunizations - Historical. The CPT code set is identified as a terminology standard for Representing Immunizations – Administered, so therefore, it should be included as a standard for historical immunizations. CPT was created over 50 years ago and is a 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.

    NCPDP Comment

    1. Request ONC to add NDC as a value. NDC has historically been used by pharmacy to report immunizations.
    2. Add the following:

    Type-Implementation Specification

    Standard Implementation/Specification- National Drug Code

    Standards Process Maturity – Final

    Implementation Maturity- Production

    Adoption Level – 5

    Federally Required – Yes

    Cost – Free

    Test Tool Availability – N/A

    Agree, it should not be…

    Agree, it should not be required because it can't be obtained from a patient's history.

    RxNorm and Immunizations?

    These are the correct value sets to represent Historical immunizations. 

    RxNorm is included in list of value and starter sets. (RxNorm Vaccine Clinical Drug 2.16.840.1.113762.1.4.1010.8)

    If CVX and MVX have it covered what is the use case for RxNorm?