NCPDP Comment

  1. Request ONC add ICD-10 as a value. In NCPDP SCRIPT Standard Version 2017071 when clinical problems are reported, ICD-10 is required and SNOMED CT® is optional.
  2. Add the following:

Type-Implementation Specification

Standard Implementation/Specification- ICD-10

Standards Process Maturity – Final

Implementation Maturity- Production

Adoption Level – 4

Federally Required – Yes

Cost – $

Test Tool Availability – Yes

  1. Include Test Tool Link:

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, outcomes, 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 2nd and 3rd bullets both describe post-coordination and could be combined into one.
  • 'left leg fracture' now has a single SNOMED CT code; ‘left kidney stone’ could be used instead as an example of post-coordination.

Agree with Rob McClure,…

Agree with Rob McClure, LOINC does NOT seem appropriate in this context.

Use of LOINC needs more explanation

Not sure how LOINC would be used. You should explain how that code system is appropriate here.