Type | Standard / Implementation Specification | Standards Process Maturity | Implementation Maturity | Adoption Level | Federally required | Cost | Test Tool Availability |
---|---|---|---|---|---|---|---|
Standard
|
Final
|
Production
|
Feedback Requested |
No
|
Free
|
N/A
|
|
Standard
|
Final
|
Production
|
Feedback Requested |
No
|
Free
|
N/A
|
Limitations, Dependencies, and Preconditions for Consideration |
Applicable Value Set(s) and Starter Set(s)
|
---|---|
|
Comment
Submitted by jkegerize on
ACLA ISA comment re: clarification to section title, ‘actors’, a
The title of this section is more limited than what is covered in this section; please clarify the actors this section applies to, e.g., Electronic Health Record (EHR) systems, Laboratory Information Systems (LIS), laboratories, exchanges, etc. Refer to the IHE LAW and LTW profiles “Intended Audience”; is the target audience the same for this section?
Some of these statements should be in the “Content/Structure” section of the ISA, not the “Vocabulary/Code Set/Terminology” section; there is overlap with the “Exchanging InVitro Diagnostics (IVD) Test Orders & Results” Content /Structure section of the ISA.
Please clarify the term “harmonization status”. We suggest this term be removed until it can be further clarified for expected implementation, clearly measured, etc. It is too nebulous as currently stated. For example, can it be measured and if so, how is it validated and how does it relate to the laboratory values/results or provider’s EHR system laboratory values/results?
Do these terms, such as “standard scales” or “grading schemes” represent the end result of using of standard terminology such as LOINC or SNOMED CT? Please clarify.
Submitted by gldickinson on
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.
Submitted by jkegerize on
ACLA Comments on Representing Result Values
The American Clinical Laboratory Association comments pertain to the burden of using the Unified Code for Units of Measure (UCUM).
ACLA agrees that the vocabulary standard, UCUM, should not be required, but may be represented. Laboratories should be allowed to use units of measure other than UCUM. The unit of measure provided by the instrument manufacturers, including FDA authorized, cleared, or approved method, is the standard that laboratories need to adhere to for result reporting. We recommend conversations and adoption from instrument manufacturers is incumbent for the adoption of UCUM to be viable.
The UCUM can be a preferred standard, but it should not be required for all tests. Currently, there is a large base of units of measure that are in use across trading partners. To convert these units to UCUM would be problematic, difficult to achieve and time consuming.
While ACLA acknowledges UCUM as an option for standardized vocabulary for units of measure it is crucial to recognize and understand the limitations of the UCUM coding system and the impact of key issues identified by ACLA prior to universal adoption.