|Type||Standard Implementation/Specification||Standards Process Maturity||Implementation Maturity||Adoption Level||Federally required||Cost||Test Tool Availability|
|Limitations, Dependencies, and Preconditions for Consideration||Applicable Value Set(s) and Starter Set(s)|
On behalf of American Medical Association (AMA) I appreciate the ability to comment on the 2017 Interoperability Standards Advisory.
The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in I-I: Lab Tests – Interoperability Need: Representing Laboratory Tests. The CPT code set contains a comprehensive and regularly curated list of laboratory tests and nomenclature. Of particular note are the Multianalyte Assay with Algorithmic Analyses (MAAA) codes, Molecular Pathology Tier 1 and Tier 2 codes, and the new Proprietary Laboratory Analyses (PLA) section of CPT. The Molecular Pathology section addresses a growing need to identify specific laboratory procedures involving the analyses of nucleic acid to detect variants in genes. The PLA section identifies clinical diagnostic laboratory tests (CDLTs), as well as tests that CMS designates as advanced diagnostic laboratory tests (ADLTs). The PLA section is designed to include the full range of medical laboratory tests including, but not limited to, MAAA and Genomic Sequencing Procedures. CPT has a high level of maturity for its development process and implementation, and is the most widely adopted outpatient procedure code set. It is also federally required.
LOINC is absolutely right for coding tests. CPT is OK, but lacks the specificity that LOINC has.
SNOMED CT is good for microbacterial susceptibility, and certain other kinds of values, but that needs more clarity in the ISA.
UCUM should be considered for units.
We strongly concur with the listing of LOINC and SNOMED CT for this interoperability need, and is the solution being used successfully in many countries.