Representing Patient Functional Status and/or Disability

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Type Standard / Implementation Specification Standards Process Maturity Implementation Maturity Adoption Level Federally required Cost Test Tool Availability
Standard for observations
Final
Production
Rating 3
No
Free
N/A
Standard for observation values
Final
Production
Rating 3
No
Free
N/A
Limitations, Dependencies, and Preconditions for Consideration
Applicable Value Set(s) and Starter Set(s)

Comment

None of the three existing…

None of the three existing CMS assessment tools for functional status assessment (MDS, OASIS, IRF-PAI) adequately covers all patients.  We need a uniform assessment instrument.

The standards named in this…

The standards named in this domain (LOINC and SNOMED CT) are appropriate and we concur with their inclusion here. However, a couple of clarifications are needed. The first bullet should be removed as it suggests that the CMS-required MDS should be used more widely and in different settings than for which it is designed. The IMPACT Act requires that CMS make certain assessment data elements standardized and interoperable so that this data may be exchanged and used by post-acute care and other providers to support care coordination and improved outcomes. CMS is working directly with the Regenstrief Institute to represent all data elements in the assessment instruments they require in different care settings (e.g. MDS, LCDS, IRF-PAI, and OASIS) in LOINC. This work includes current versions of these instruments, as well as their intended harmonization over time. 

In addition, many clinical assessments of functional status are well represented in LOINC and SNOMED CT.

AMA's comments to ONC on proposed 2018 ISA

On behalf of American Medical Association (AMA) I appreciate the ability to comment on the 2018 Interoperability Standards Advisory (ISA).

Comment:

The AMA recommends adding the “Guides to the Evaluation of Permanent Impairment, Sixth Edition” (“Guides”) as an additional resource for this interoperability need in the Limitations, Dependencies, and Preconditions for Consideration.  The Guides are a standardized, objective approach to conducting impairment ratings that result in detailed documentation of functional outcomes, physical findings, and clinical test results and have been shown to improve the overall consistency, transparency, and precision of impairment ratings.  Users include physicians, other health care providers, attorneys, employers, and claims professionals.  The Guides are adopted by U.S. Department of Labor’s Division of Federal Employees’ Compensation for schedule award entitlement determinations.  They are also adopted in 19 states and used internationally in Canada, Australia, New Zealand, Hong Kong, Korea, South Africa, and The Netherlands.