Representing Patient Clinical “Problems” (i.e., Conditions)

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Comment

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.

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: https://tools.ncpdp.org/erx/#/home