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This file is created on 2025-01-17 05:02:52am

About the ISA

Comment

Over recent years, the…

Over recent years, the healthcare industry has undergone a huge digital transformation due to the need to completely update its existing infrastructure.

ISA Comments from Washington State Department of Health

Please refer to the attached comments from the Washington State Department of Health. Thank you for the opportunity to comment.

WA_DOH_Comments_ONC_ISA_2023.pdf

AMIA's Comments on the ONC ISA 2024 Reference Edition

Please see attached the American Medical Informatics Association's feedback on the 2024 ISA Reference Edition. Thank you for the opportunity to comment.

AMIA-ONC-ISA-Public-Comment-Letter.pdf

AMIA's Comments on the ONC ISA 2024 Reference Edition

Please see attached the American Medical Informatics Association's feedback on the 2024 ISA Reference Edition. Thank you for the opportunity to comment.

 

AMIA-ONC-ISA-Public-Comment-Letter.pdf

AMIA's Comments on the ONC ISA 2024 Reference Edition

Please see attached the American Medical Informatics Association's feedback on the 2024 ISA Reference Edition. Thank you for the opportunity to comment.

AMIA-ONC-ISA-Public-Comment-Letter.pdf

HL7's Feedback on the 2024 ISA Reference Edition

Please see attached Health Level Seven International's feedback on the 2024 ISA Reference Edition. Thank you for the opportunity to comment.

HL7 Response ISA Letter 10.05.23 Final.pdf

APHL Comments on ISA 2022

APHL strongly supports the mission of the Interoperability Standards Advisory (ISA) and thus is respectfully submitting the following comments on the current version of the ISA

Vocabulary/Code Set/Terminology Standards and Implementation Specifications

General comment for this section:

In several sections the ISA lists implementation guides rather than linking to the explicit vocabulary defined in those guides (for example HL7 FHIR (v4.0.1) Situational Awareness for Novel Epidemic Response (SANER) IG 0.1.0 Continuous Build and the Logica COVID-19 (FHIR v4.0.1) Implementation Guide CI Build under COVID-19 Novel Coronavirus Pandemic , or in the referenced FHIR resources NutritionIntake  and NutritionProduct under Representing Nutrition Assessment, Diagnosis, Interventions and Monitoring/Evaluation).

#1: Suggest to review and update with the respective code systems (or value sets, if appropriate to constrain to that level).

 

- Representing Non-imaging and Non-laboratory Clinical Tests:

Currently the section under “Limitations, Dependencies, and Preconditions for Consideration” includes a bullet explaining that this attribute really consists at minimum of 2 elements,

#1 Suggest to split attribute into “Clinical Test performed” and “Clinical Test Result Value” as a main section to avoid confusion when different code systems are suggested. That way it is clear that LOINC is the coding system to identify the “Clinical Test performed”, while SNOMED CT, mostly drawn from the clinical finding hierarchy, should be used when codifying results under “Clinical Test Result Value”. Other code systems useful in this context are Unified Units of Measure (UCUM) when numeric results are reported – this is described as its own attribute (Representing Units of Measure (For Use with Numerical References and Values), but the association to result values should be pointed out here.

 

- Laboratory

-- Representing Laboratory Test Ordered

This section is missing a separate category for Specimen, which should point to SNOMED CT (from the specimen hierarchy).

#1 Suggest to add a new attribute “Specimen information” which should have the following sub-attributes, some of which are mentioned in the USCDI:

Specimen Type – referencing SNOMED CT (from the specimen hierarchy)

Specimen source site – referencing SNOMED CT (from the body structure and physical object hierarchies)

Source site modifier – referencing SNOMED CT (from the qualifier hierarchy)

Specimen collection method – referencing SNOMED CT (from the procedure hierarchy)

 

The reference to CPT is confusing as the goal is to order lab tests using LOINC wherever possible (as further defined in the Laboratory Order Interface (LOI) Implementation Guide in the Ordering Laboratory Tests for a Patient section) and the use of CPT is uncommon in this use case.  CPT codes are commonly used for billing, which should be a separate section under laboratory to accommodate the administrative use case.

#2 Suggest to remove CPT from this section and create a separate section “Representing Laboratory Test in Billing” where CPT should be listed – with the same attributes as currently in this section.

 

Content/Structure

- Laboratory

-- Exchanging InVitro Diagnostics (IVD) Test Orders & Results

LIVD – Digital Format for Publication of LOINC to Vendor IVD Test Results :

#1 Suggest to remove the ‘$’ in the “Cost” column as there is no cost associated with accessing or using this implementation guide.

 

-- Ordering Laboratory Tests for a Patient

#1Suggest to update HL7 Version 2.5.1 Implementation Guide: Laboratory Orders from EHR (LOI) Release 1, STU Release 3 - US Realm to the latest version of LOI version (will provide updated name and hyperlink once published in October 2022)

#2 Suggest to update the HL7 Version 2 Implementation Guide: Laboratory Value Set Companion Guide Release 1, STU Release 3 - US Realm HL7 Standard for Trial Use to the latest version (will provide updated name and hyperlink once published in October 2022) in support of LOI

#3 Suggest to add this Implementation Guide from Jan 2021: HL7 Version 2.5.1 Implementation Guide: Standards & Interoperability (S&I) Framework Laboratory Test Compendium Framework (eDOS) Ask at Order Entry (AOE) Release 2, STU Release 3.1 - US Realm because it provides guidance on using the most common Ask at Order Entry questions; “Adoption Level” Emerging Standard. Of note is that this IG is not explicitly implemented, but rather used as a resource by laboratories when setting up their catalog and order messages.

 

-- Receive Electronic Laboratory Test Results

#1 Suggest to update HL7® Version 2.5.1 Implementation Guide: Lab Results Interface (LRI) Release 1, STU Release 3 - US Realm to the latest version of LOI version (will provide updated name and hyperlink once published in October 2022)

#2 Suggest to HL7® Version 2 Implementation Guide: Laboratory Value Set Companion Guide Release 1, STU Release 3 - US Realm, June 2018 to the latest version (will provide updated name and hyperlink once published in October 2022) in support of LRI

#3 Suggest to add the following text into “Limitations, Dependencies, and Preconditions for Consideration”: While the HL7® Version 2.5.1 Implementation Guide: S&I Framework Lab Results Interface, Release 1—US Realm [HL7 Version 2.5.1: ORU_R01] Draft Standard for Trial Use, July 2012 was named in Meaningful Use and may thus be implemented at a few sites, the recommended standard for new implementations is <the new version of  HL7® Version 2.5.1 Implementation Guide: Lab Results Interface (LRI) Release 1, STU Release 3 - US Realm> because that is the specification that is actively being maintained and updated with new use cases, when needed.

 

-- Support the Transmission of a Laboratory’s Directory of Services to Provider’s Health IT or EHR System

#1 Suggest to HL7® Version 2 Implementation Guide: Laboratory Value Set Companion Guide Release 1, STU Release 3 - US Realm, June 2018 to the latest version (will provide updated name and hyperlink once published in October 2022) in support of eDOS

#2 Suggest to add HL7 Version 2.5.1 Implementation Guide: Standards & Interoperability (S&I) Framework Laboratory Test Compendium Framework (eDOS) Ask at Order Entry (AOE) Release 2, STU Release 3.1 (US Realm), because prior to this release this content was published as Appendix A in a single document as part of HL7 Version 2.5.1 Implementation Guide: S&I Framework Laboratory Test Compendium Framework (eDOS) Release 2, STU Release 3 (US Realm). In 2021, the AOE content was published separately for greater visibility and because it is standard agnostic, except for the data types which may be different for HL7 V2 vs. HL7 FHIR. There is an HL7 project (1634) to publish an update in the future to also reference FHIR datatypes.

 

-- Unique Device Identification

#1 Suggest to update HL7 Cross-Paradigm Implementation Guide: UDI Pattern, Release 1 to the latest release: HL7 Cross Paradigm Implementation Guide: UDI Pattern, Release 2  for all sub-points in this section (Defining a Globally Unique Device Identifier, Representing Unique Implantable Device Identifiers and Transmitting a Unique Device Identifier); its adoption level should be increased since this is being used as building blocks for implementation of other IGs in certified systems across the US.

CAQH CORE Comments on the ONC ISA Annual Update

  • CAQH CORE appreciates the opportunity to provide content updates for the 2023 ISA Reference Edition and web version.
  • CAQH CORE has proposed several substantive updates including the addition of two new Operating Rule Sets supporting value-based payment and requirements to ensure secure and consistent connectivity between trading partners. Details surrounding these Operating Rules, including the language that is proposed for entry into the 2023 ISA Reference Edition and web version, are in the attached document on pages 4-5.
  • Non-substantive updates include edits to address consistency in naming conventions, the order that CAQH CORE Operating Rules appear on the web version of ISA and the 2023 ISA Reference Edition, and other grammar and syntax corrections. These changes are interspersed throughout the attached document highlighted in gray. Proposed deletions are highlighted gray and shown with strikethrough text.
  • Additional comments have been entered into the web version of the ISA for each CAQH CORE Operating Rule directing the reader to the pages in the attached document where changes have been made.

CAQH CORE ISA Letter 2022.pdf

ACLA ISA comment re: Annual Reference Edition

We appreciate the annual Reference Edition .pdf, but Is it also possible to get a revision marked version of the annual draft for comment and reference edition ISA in future? Narrowing the review to content that has changed will allow us greater focus on future comments.

ISA Structure

Comment

Greater Emphasis on Testing Tools

HIMSS encourages ONC to determine how best to incorporate information on the testing of standards into ISA.  When the community looks at any standard, no matter how well the standard is written, it is the actual implementation of that standard where there is interpretation variability.  Overall, the community spends a significant amount of time talking about standards and implementation guides, but if those standards and guides are not tested once embedded into products and systems, there are questions about whether stakeholders are making the progress needed to propel broader interoperability efforts forward.    

 

HIMSS would like ISA to include more quantitative data to support the assessment of standards adoption/maturity.  For example, one helpful approach would be to include more information about testing, test tools, testing events, as well as how and where particular standards can be tested and advanced.  We encourage ONC to work with Integrating the Healthcare Enterprise (IHE) and Health Level Seven International (HL7) to investigate whether the upcoming connectathon events that each organization sponsors would be the appropriate setting to provide additional quantitative data in support of this effort.  HIMSS would be interested in working with ONC to ascertain whether this idea is best suited for more references within ISA or to build out more robust testing standards as part of the Interoperability Proving Ground

 

It is also important to note ONC’s reference to testing in the preamble to ISA, and how the agency encourages further pilot testing and industry experience to be sought with respect to standards and implementation specifications identified as “emerging” in ISA.  HIMSS would like to be helpful resource to ONC on this type of project. 

 

ISA Timeline and Comment Process

Comment

Nice

Nice

Thank you for the…

Thank you for the opportunity to comment on the new version of Interoperability Standards Advisory (ISA) 2024. The attached comments are provided on behalf of Washington State Department of Health.

ISA 2024 Comments WA DOH.docx

CAQH CORE 2025 ISA Updates

CAQH CORE reviewed the ISA and indicated recommended edits in the attached comment letter. 

CORE Submission_2025 ISA Updates.pdf

NEW ISA platform

The FEHRM has reviewed the ISA website and submitted the attached file with our comments.

ASI_Comments_08062024-.docx

Integration of Continuous Glucose Monitor Data into the EHR

A consensus group of 130 stakeholders (organized by Diabetes Technology Society) from academia, government, and industry developed iCoDE with data standards and workflow processes for integrating the wearable device Continuous Glucose Monitors into the EHR. The iCoDE standard contained 54 recommendations when it was completed in November 2022.  Many of its terms for expressing results of CGM testing are worthy of adoption by the (next) USCDI 5.  The link to the iCoDE standard is here: <https://www.diabetestechnology.org/icode/>

DirectTrust ISA Updates - 2023

Updates to links for permanence. Updates to adoption levels. Inclusion of Context IG now that it is in use in the Notifications Standard.  ANSI Naming added to ANSI approved standards.

ISA Updates 2023 0 DirectTrust.xlsx

CORE Response to the 2024 ISA Open Comment Period

Thank you for the opportunity to provide substantive recommendations that promote consistency and update the content of the ISA. Comprehensive responses from CORE can be found at this link: CORE Submission for the 2024 ISA Open Comment Period. This link has also been posted to relevant pages throughout the ISA, referencing page numbers where edits can be found.

Please note, on page 2 of the linked letter, CORE has made several recommendations that ensure consistency of Operating Rule nomenclature across all pages of the ISA.

Please do not hesitate to contact us with questions.

FAQs

Comment

Incomplete demographic data in COVID-19 reports

Is anyone monitoring the completeness of data that is being exchanged? During COVID-19, many states published summaries of their data including demographic information. Some have been very transparent in reporting missing data e.g. Florida. Is there a national effort to monitor the completeness of the data that is being exchanged and to look for ways to improve it. 

Here is a summary of one of Florida's recent COVID-19 reports showing missing data from page 8: https://tinyurl.com/3vnmn6vy 

       Cumulative COVID-19 cases:

                    Unknown gender: 83,415 of 7,646,882 or 1.1 %

                    Unknown race: 545,211 of 7,646,882 or 7.1 %

           

     Cumulative COVID-19 vaccinated:

                    Unknown gender: 24,910 of 16,259,122 or 0.1 %

                    Unknown race: 1,717,175 of 16,259,122 or 10.6 %

    How can we improve health equity if the basic demographic data are incomplete? Are there standards that systems are trying to meet? 0.1 % missing gender sounds pretty good but 10.6 % missing race does not sound good at all. My personal experience with our EHR (Athenanet) and its data exchange with our state's immunization registry is that immunization data is exchanged but patient demographic information is not. Is that a requirement for a system to be ONC certified? Thanks.

About the ISA

Comment

Over recent years, the…

Over recent years, the healthcare industry has undergone a huge digital transformation due to the need to completely update its existing infrastructure.

ISA Comments from Washington State Department of Health

Please refer to the attached comments from the Washington State Department of Health. Thank you for the opportunity to comment.

WA_DOH_Comments_ONC_ISA_2023.pdf

AMIA's Comments on the ONC ISA 2024 Reference Edition

Please see attached the American Medical Informatics Association's feedback on the 2024 ISA Reference Edition. Thank you for the opportunity to comment.

AMIA-ONC-ISA-Public-Comment-Letter.pdf

AMIA's Comments on the ONC ISA 2024 Reference Edition

Please see attached the American Medical Informatics Association's feedback on the 2024 ISA Reference Edition. Thank you for the opportunity to comment.

 

AMIA-ONC-ISA-Public-Comment-Letter.pdf

AMIA's Comments on the ONC ISA 2024 Reference Edition

Please see attached the American Medical Informatics Association's feedback on the 2024 ISA Reference Edition. Thank you for the opportunity to comment.

AMIA-ONC-ISA-Public-Comment-Letter.pdf

HL7's Feedback on the 2024 ISA Reference Edition

Please see attached Health Level Seven International's feedback on the 2024 ISA Reference Edition. Thank you for the opportunity to comment.

HL7 Response ISA Letter 10.05.23 Final.pdf

APHL Comments on ISA 2022

APHL strongly supports the mission of the Interoperability Standards Advisory (ISA) and thus is respectfully submitting the following comments on the current version of the ISA

Vocabulary/Code Set/Terminology Standards and Implementation Specifications

General comment for this section:

In several sections the ISA lists implementation guides rather than linking to the explicit vocabulary defined in those guides (for example HL7 FHIR (v4.0.1) Situational Awareness for Novel Epidemic Response (SANER) IG 0.1.0 Continuous Build and the Logica COVID-19 (FHIR v4.0.1) Implementation Guide CI Build under COVID-19 Novel Coronavirus Pandemic , or in the referenced FHIR resources NutritionIntake  and NutritionProduct under Representing Nutrition Assessment, Diagnosis, Interventions and Monitoring/Evaluation).

#1: Suggest to review and update with the respective code systems (or value sets, if appropriate to constrain to that level).

 

- Representing Non-imaging and Non-laboratory Clinical Tests:

Currently the section under “Limitations, Dependencies, and Preconditions for Consideration” includes a bullet explaining that this attribute really consists at minimum of 2 elements,

#1 Suggest to split attribute into “Clinical Test performed” and “Clinical Test Result Value” as a main section to avoid confusion when different code systems are suggested. That way it is clear that LOINC is the coding system to identify the “Clinical Test performed”, while SNOMED CT, mostly drawn from the clinical finding hierarchy, should be used when codifying results under “Clinical Test Result Value”. Other code systems useful in this context are Unified Units of Measure (UCUM) when numeric results are reported – this is described as its own attribute (Representing Units of Measure (For Use with Numerical References and Values), but the association to result values should be pointed out here.

 

- Laboratory

-- Representing Laboratory Test Ordered

This section is missing a separate category for Specimen, which should point to SNOMED CT (from the specimen hierarchy).

#1 Suggest to add a new attribute “Specimen information” which should have the following sub-attributes, some of which are mentioned in the USCDI:

Specimen Type – referencing SNOMED CT (from the specimen hierarchy)

Specimen source site – referencing SNOMED CT (from the body structure and physical object hierarchies)

Source site modifier – referencing SNOMED CT (from the qualifier hierarchy)

Specimen collection method – referencing SNOMED CT (from the procedure hierarchy)

 

The reference to CPT is confusing as the goal is to order lab tests using LOINC wherever possible (as further defined in the Laboratory Order Interface (LOI) Implementation Guide in the Ordering Laboratory Tests for a Patient section) and the use of CPT is uncommon in this use case.  CPT codes are commonly used for billing, which should be a separate section under laboratory to accommodate the administrative use case.

#2 Suggest to remove CPT from this section and create a separate section “Representing Laboratory Test in Billing” where CPT should be listed – with the same attributes as currently in this section.

 

Content/Structure

- Laboratory

-- Exchanging InVitro Diagnostics (IVD) Test Orders & Results

LIVD – Digital Format for Publication of LOINC to Vendor IVD Test Results :

#1 Suggest to remove the ‘$’ in the “Cost” column as there is no cost associated with accessing or using this implementation guide.

 

-- Ordering Laboratory Tests for a Patient

#1Suggest to update HL7 Version 2.5.1 Implementation Guide: Laboratory Orders from EHR (LOI) Release 1, STU Release 3 - US Realm to the latest version of LOI version (will provide updated name and hyperlink once published in October 2022)

#2 Suggest to update the HL7 Version 2 Implementation Guide: Laboratory Value Set Companion Guide Release 1, STU Release 3 - US Realm HL7 Standard for Trial Use to the latest version (will provide updated name and hyperlink once published in October 2022) in support of LOI

#3 Suggest to add this Implementation Guide from Jan 2021: HL7 Version 2.5.1 Implementation Guide: Standards & Interoperability (S&I) Framework Laboratory Test Compendium Framework (eDOS) Ask at Order Entry (AOE) Release 2, STU Release 3.1 - US Realm because it provides guidance on using the most common Ask at Order Entry questions; “Adoption Level” Emerging Standard. Of note is that this IG is not explicitly implemented, but rather used as a resource by laboratories when setting up their catalog and order messages.

 

-- Receive Electronic Laboratory Test Results

#1 Suggest to update HL7® Version 2.5.1 Implementation Guide: Lab Results Interface (LRI) Release 1, STU Release 3 - US Realm to the latest version of LOI version (will provide updated name and hyperlink once published in October 2022)

#2 Suggest to HL7® Version 2 Implementation Guide: Laboratory Value Set Companion Guide Release 1, STU Release 3 - US Realm, June 2018 to the latest version (will provide updated name and hyperlink once published in October 2022) in support of LRI

#3 Suggest to add the following text into “Limitations, Dependencies, and Preconditions for Consideration”: While the HL7® Version 2.5.1 Implementation Guide: S&I Framework Lab Results Interface, Release 1—US Realm [HL7 Version 2.5.1: ORU_R01] Draft Standard for Trial Use, July 2012 was named in Meaningful Use and may thus be implemented at a few sites, the recommended standard for new implementations is <the new version of  HL7® Version 2.5.1 Implementation Guide: Lab Results Interface (LRI) Release 1, STU Release 3 - US Realm> because that is the specification that is actively being maintained and updated with new use cases, when needed.

 

-- Support the Transmission of a Laboratory’s Directory of Services to Provider’s Health IT or EHR System

#1 Suggest to HL7® Version 2 Implementation Guide: Laboratory Value Set Companion Guide Release 1, STU Release 3 - US Realm, June 2018 to the latest version (will provide updated name and hyperlink once published in October 2022) in support of eDOS

#2 Suggest to add HL7 Version 2.5.1 Implementation Guide: Standards & Interoperability (S&I) Framework Laboratory Test Compendium Framework (eDOS) Ask at Order Entry (AOE) Release 2, STU Release 3.1 (US Realm), because prior to this release this content was published as Appendix A in a single document as part of HL7 Version 2.5.1 Implementation Guide: S&I Framework Laboratory Test Compendium Framework (eDOS) Release 2, STU Release 3 (US Realm). In 2021, the AOE content was published separately for greater visibility and because it is standard agnostic, except for the data types which may be different for HL7 V2 vs. HL7 FHIR. There is an HL7 project (1634) to publish an update in the future to also reference FHIR datatypes.

 

-- Unique Device Identification

#1 Suggest to update HL7 Cross-Paradigm Implementation Guide: UDI Pattern, Release 1 to the latest release: HL7 Cross Paradigm Implementation Guide: UDI Pattern, Release 2  for all sub-points in this section (Defining a Globally Unique Device Identifier, Representing Unique Implantable Device Identifiers and Transmitting a Unique Device Identifier); its adoption level should be increased since this is being used as building blocks for implementation of other IGs in certified systems across the US.

CAQH CORE Comments on the ONC ISA Annual Update

  • CAQH CORE appreciates the opportunity to provide content updates for the 2023 ISA Reference Edition and web version.
  • CAQH CORE has proposed several substantive updates including the addition of two new Operating Rule Sets supporting value-based payment and requirements to ensure secure and consistent connectivity between trading partners. Details surrounding these Operating Rules, including the language that is proposed for entry into the 2023 ISA Reference Edition and web version, are in the attached document on pages 4-5.
  • Non-substantive updates include edits to address consistency in naming conventions, the order that CAQH CORE Operating Rules appear on the web version of ISA and the 2023 ISA Reference Edition, and other grammar and syntax corrections. These changes are interspersed throughout the attached document highlighted in gray. Proposed deletions are highlighted gray and shown with strikethrough text.
  • Additional comments have been entered into the web version of the ISA for each CAQH CORE Operating Rule directing the reader to the pages in the attached document where changes have been made.

CAQH CORE ISA Letter 2022.pdf

ACLA ISA comment re: Annual Reference Edition

We appreciate the annual Reference Edition .pdf, but Is it also possible to get a revision marked version of the annual draft for comment and reference edition ISA in future? Narrowing the review to content that has changed will allow us greater focus on future comments.

ISA Content

Vocabulary/Code Set/Terminology Standards and Implementation Specifications

A-H
R-W

Content/Structure Standards and Implementation Specifications

A-H
I-P
Standards and Implementation Specifications for Services and Exchange
Administrative Standards and Implementation Specifications

ISA Publications

Recent ISA Updates

SVAP

View / Comment Current Standard / Implementation Specification listing in IBR (170.299) Regulatory Text Citation for Standard / Implementation Specification Adopted Sort descending Certification Criteria(on) References Standard / Implementation Specification National Coordinator Approved Advanced Version(s) View / Comment
§ 170.202(a)(2)


§ 170.202(b)
§ 170.202(d)

§ 170.202(e)(1)

§ 170.204(a)(1)
§ 170.204(a)(2)
§ 170.205(a)(3)

§ 170.205(a)(4)






§ 170.205(a)(4)






§ 170.205(a)(5)






§ 170.205(a)(6)






§ 170.205(b)(1)
§ 170.205(d)(4)
§ 170.205(d)(4)
§ 170.205(e)(4)
§ 170.205(e)(4)
§ 170.205(g)
§ 170.205(g)
§ 170.205(h)(2)

§ 170.205(h)(3)
§ 170.205(i)(2)
§ 170.205(i)(2)
§ 170.205(k)(3)
§ 170.205(o)(1)

§ 170.205(p)(1)
§ 170.205(r)(1)
§ 170.205(s)(1)
§ 170.205(s)(1)
§ 170.213





§ 170.213





§ 170.215(a)(1)
§ 170.215(a)(3)
§ 170.215(a)(3)
§ 170.215(a)(4)
§ 170.215(b)
§ 170.215(b)(1)
§ 170.215(b)(1)

1SVAP is permitted in ONC’s 21st Century Cures Act Final Rule in the Real World Testing CoC/MoC: § 170.405(b)(7) and (8) and ONC-ACB PoPC  §170.523(t)

Comment

This is a great resource!!

 The Standards Version Advancement Process (SVAP) is a crucial step in improving healthcare IT systems and ensuring they meet the latest standards. It's exciting to see such a structured approach to enhancing interoperability and advancing technology for better patient care. Kudos to the team for providing this clear and informative guide! 

FEHRM Comments

The Federal Electronic Health Records Modernization (FEHRM) Program appreciates the opportunity to review and provide feedback on ONC’s 2024 SVAP. The FEHRM understands that the SVAP allows developers to incorporate newer digital health standards. The FEHRM reviewed the list of new standard versions under consideration and supports advancing:


United States Core Data for Interoperability (USCDI) version 4

Consolidated Clinical Document Architecture (C-CDA) Release 3 

US Core 7.0.0

 

We appreciate the opportunity to comment on the SVAP. Please feel free to contact us if you have any questions or would like any further information.

 

Epic Comments on SVAP 2024

Please see the attached document with Epic's feedback on SVAP 2024. Thank you for your consideration. 

Comments on SVAP 2024 - Epic.pdf

Health Level Seven SVAP Comments

Attached are the comments from Health Level Seven International on ONC’s Standards Version Advancement Process (SVAP). Thank you for the opportunity to provide feedback! 

HL7 SVAP Letter 05.21.24 Final.pdf

CDC/NIOSH - SVAP Comments 2024

Please see attached comments for consideration.

NIOSH SVAP Comments 2024.pdf

WA State Department of Health - SVAP Comments

Please find attached our comments for the 2024 SVAP.

WA_DOH_SVAP_Comments_2024.pdf

MEDITECH Comments on 2024 SVAP

On behalf of Medical Information Technology, Inc. (MEDITECH), thank you for the opportunity to provide feedback. Please see the attached comment letter on the 2024 Standards Version Advancement Process (SVAP). 

MEDITECH 2024 SVAP Comments.pdf

EHR Association Comments on 2024 SVAP

On behalf of our 29 member companies, the HIMSS Electronic Health Record (EHR) Association appreciates the opportunity to provide feedback to the ONC on the 2024 Standards Version Advancement Process (SVAP). Our comments are attached.

EHR Association Comments to ONC on 2024 SVAP.pdf

HL7 FHIR® SMART Application Launch Framework v2.1.0

Please update the HL7 FHIR® SMART Application Launch Framework to v2.1.0 published April 28, 2023. There is an incompatibility in how SMART's "fhirContext" launch parameter is used in 2.0.0 vs 2.1.0. It would be best for all servers and clients to adopt the latest version before this incompatibility is deployed requiring servers/clients to support two formats.

Alternatively, we expect SMART v2.2.0 to be published in April/May 2024. This verson could also be considered. 

 

 

Download USCDI

Classification Level Sort descending Data Class Data Class Description Data Element Data Element Description Applicable Standards Submitter Name Submitter Organization Submission Date
USCDI V1 Clinical Notes

Narrative patient data relevant to the context identified by note types.

  •  
  • Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name. 
Consultation Note

Contains the response to request from a clinician for an opinion or advice from another clinician.

Logical Observation Identifiers Names and Codes (LOINC®) version 2.67

  • Consult Note (LOINC® code 11488-4)
USCDI V1 Clinical Notes

Narrative patient data relevant to the context identified by note types.

  •  
  • Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name. 
Discharge Summary Note

A synopsis of a patient’s admission and course in a hospital or post-acute care setting.

Logical Observation Identifiers Names and Codes (LOINC®) version 2.67

  • Discharge Summary (LOINC® code 18842-5)
USCDI V1 Patient Demographics/Information

Data used to categorize individuals for identification, records matching, and other purposes.

Last Name
USCDI V1 Laboratory

Analysis of clinical specimens to obtain information about the health of a patient.

Values/Results

Documented findings of the analysis of a tested specimen. Includes both structured and unstructured (narrative) components.

USCDI V1 Immunizations

Record of vaccine administration.

Immunizations
  • CDC IIS: Current HL7 Standard Code Set, CVX -- Vaccines Administered, updates through January 31, 2020
  • CDC National Drug Code (NDC) Directory – Vaccine NDC Linker Table, updates through January 31, 2020
USCDI V1 Goals

Desired state to be achieved by a patient.

Patient Goals

Desired outcomes of patient's care.

USCDI V1 Patient Demographics/Information

Data used to categorize individuals for identification, records matching, and other purposes.

Birth Sex

Birth sex must be coded in accordance with HL7 Version 3 (V3) Standard, Value Sets for AdministrativeGender and NullFlavor attributed as follows:

  • Female. F
  • Male. M
  • Unknown. nullFlavor UNK

Adopted at 45 CFR 170.207(n) 

USCDI V1 Health Concerns

Health related matter that is of interest, importance, or worry to someone who may be the patient, patient’s family or patient’s health care provider.

Health Concerns
USCDI V1 Patient Demographics/Information

Data used to categorize individuals for identification, records matching, and other purposes.

Suffix
USCDI V1 Patient Demographics/Information

Data used to categorize individuals for identification, records matching, and other purposes.

Race

Both standards are required

  • The Office of Management and Budget Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity, Statistical Policy Directive No. 15, as revised, October 30, 1997
  • CDC Race and Ethnicity Code Set Version 1.0 (March 2000)

Adopted at 45 CFR 170.207(f)

USCDI V1 Assessment and Plan of Treatment

Health professional’s conclusions and working assumptions that will guide treatment of the patient.

Assessment and Plan of Treatment
USCDI V1 Medications

Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.

Medications
  • RxNorm®, January 6, 2020 Full Release Update
USCDI V1 Patient Demographics/Information

Data used to categorize individuals for identification, records matching, and other purposes.

Middle Name (including middle initial)
USCDI V1 Clinical Notes

Narrative patient data relevant to the context identified by note types.

  •  
  • Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name. 
History & Physical

Documents the current and past conditions and observations of the patient.

Logical Observation Identifiers Names and Codes (LOINC®) version 2.67

  • Discharge Summary (LOINC® code 34117-2)
USCDI V1 Patient Demographics/Information

Data used to categorize individuals for identification, records matching, and other purposes.

First Name
USCDI V1 Clinical Notes

Narrative patient data relevant to the context identified by note types.

  •  
  • Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name. 
Procedure Note

Encompasses non-operative procedures including interventional cardiology, gastrointestinal endoscopy, osteopathic manipulation, and other specialty’s procedures.

Logical Observation Identifiers Names and Codes (LOINC®) version 2.67

  • Procedure Note (LOINC® code 28570-0)
USCDI V1 Clinical Notes

Narrative patient data relevant to the context identified by note types.

  •  
  • Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name. 
Progress Note

Represents a patient’s interval status during a hospitalization, outpatient visit, treatment with a post-acute care provider, or other healthcare encounter.

Logical Observation Identifiers Names and Codes (LOINC®) version 2.67

  • Progress Note (LOINC® code 11506-3)
USCDI V1 Patient Demographics/Information

Data used to categorize individuals for identification, records matching, and other purposes.

Previous Name
USCDI V1 Laboratory

Analysis of clinical specimens to obtain information about the health of a patient.

Tests

The name of the analysis of specimens derived from humans which provide information for the diagnosis, prevention, treatment of disease, or assessment of health.

  • Logical Observation Identifiers Names and Codes (LOINC®) version 2.67
USCDI V1 Patient Demographics/Information

Data used to categorize individuals for identification, records matching, and other purposes.

Date of Birth

Download USCDI Comments

Page Type Posted in Subject Author Post date Data Class or Data Element Name
Data Class Observations Observation class - Surgical Observation (new data element) dshekhar18 Observations
Data Element Health Concerns Updates Angelicah1215 Health Concerns
Data Element Unique Device Identifier (UDI) Support for “Unique Device Identifier” data element james.tcheng@duke.edu Unique Device Identifier (UDI)
Data Element Immunizations Rename the data element Immunizations to Vaccine Code nedragarrett_CDC Immunizations
Data Class Immunizations Rename the data element Immunizations to Vaccine Code nedragarrett_CDC Immunizations
Data Element Medical Record Number Medical Record Number nedragarrett_CDC Medical Record Number
Data Element Mother's Maiden Name Mother’s Maiden Name nedragarrett_CDC Mother's Maiden Name
Data Element Vaccination Event Record Type Vaccination Event Record Type nedragarrett_CDC Vaccination Event Record Type
Data Element Vaccination Administration Date Vaccination Administration Date nedragarrett_CDC Vaccination Administration Date
Data Class Diagnostic Imaging Inclusion of Diagnostic Imaging Report in USCDI v6 mitrarocca Diagnostic Imaging
Data Element Procedures Procedures AndreaP Procedures
Data Element Laboratory Order Laboratory Order AndreaP Laboratory Order
Data Element Condition and Disposition of Specimens Specimen Condition… AndreaP Condition and Disposition of Specimens
Data Class Diagnostic Imaging Diagnostic Imaging - Imaging Links in USCDI V6 ccarr_rsna Diagnostic Imaging
Data Element Mother's Maiden Name CSTE Comment - v6 BLampkins_CSTE Mother's Maiden Name
Data Element Provider NPI CSTE Comment - v6 BLampkins_CSTE Provider NPI
Data Element Medicare Patient Identifier CSTE Comment - v6 BLampkins_CSTE Medicare Patient Identifier
Data Element Estimated Date of Delivery CSTE Comment - v6 BLampkins_CSTE Estimated Date of Delivery
Data Element Travel History Dates CSTE Comment - v6 BLampkins_CSTE Travel History Dates
Data Element Travel History Location CSTE Comment - v6 BLampkins_CSTE Travel History Location
Data Element Patient Identifier Type CSTE Comment - v6 BLampkins_CSTE Patient Identifier Type
Data Element Date of Onset CSTE Comment - v6 BLampkins_CSTE Date of Onset
Data Element Vaccination Administration Date CSTE Comment - v6 BLampkins_CSTE Vaccination Administration Date
Data Element Vaccination Event Record Type CSTE Comment - v6 BLampkins_CSTE Vaccination Event Record Type
Data Element Usual Occupation CSTE Comment - v6 BLampkins_CSTE Usual Occupation
Data Element Usual Industry CSTE Comment - v6 BLampkins_CSTE Usual Industry
Data Element Test Kit Unique Identifier CSTE Comment - v6 BLampkins_CSTE Test Kit Unique Identifier
Data Element Specimen Collection Method CSTE Comment - v6 BLampkins_CSTE Specimen Collection Method
Data Element Specimen collection date/time CSTE Comment - v6 BLampkins_CSTE Specimen collection date/time
Data Element Pregnancy Outcome CSTE Comment - v6 BLampkins_CSTE Pregnancy Outcome
Data Class Advance Directives PACIO Recommends Advancing Data Class and Data Element HCapon Advance Directives
Data Element Device used PACIO Recommends Advancing Device Used HCapon Device used
Data Element Employment Status CDC comments on Employment Status nedragarrett_CDC Employment Status
Data Element Nutrition Status PACIO Recommends Advancing Nutrition Status HCapon Nutrition Status
Data Element Education Level CDC comments on Education Level nedragarrett_CDC Education Level
Data Class Orders PACIO Supports Inclusion of Nutrition Order HCapon Orders
Data Element Patient Social Security Number CDC comments on Patient's Social Security Number nedragarrett_CDC Patient Social Security Number
Data Element Pregnancy Outcome CDC comments on Pregnancy Outcome nedragarrett_CDC Pregnancy Outcome
Data Element Gestational Age CDC comments on Gestational Age nedragarrett_CDC Gestational Age
Data Element Estimated Date of Delivery CDC comment on Estimated Date of Delivery nedragarrett_CDC Estimated Date of Delivery
Data Class Health Status Assessments PACIO Requests Expansion of Definitions HCapon Health Status Assessments
Data Element Patient Communication Status PACIO Recommends Changes to Patient Comm Status HCapon Patient Communication Status
Data Element Portable Medical Orders for Life-Sustaining Treatments PACIO Recommends Removal of PMOLST Data Element HCapon Portable Medical Orders for Life-Sustaining Treatments
Data Class Medications CDC comment on MedicationAdministration Resource nedragarrett_CDC Medications
Data Element Orders for End of Life Care PACIO Supports Portable Medical Order in V6 HCapon Orders for End of Life Care
Data Class Health Status Assessments PACIO Support for ICF as an Applicable Vocabulary Standard HCapon Health Status Assessments
Data Element Medication Administered Reason Reference CSTE Comment - v6 BLampkins_CSTE Medication Administered Reason Reference
Data Element Medication Prescribed Dose CSTE Comment - v6 BLampkins_CSTE Medication Prescribed Dose
Data Element Medication Prescribed Code CSTE Comment - v6 BLampkins_CSTE Medication Prescribed Code
Data Element Medication Administration Dose Units CSTE Comment - v6 BLampkins_CSTE Medication Administration Dose Units

USCDI+

Introduction

Comment

Timeline graphic and federal agency input

Consider adding the USCDI and USCDI data elements to the timeline graphic and the HL7 FHIR US Core web page.

  • Could include the first versions rolled out and (possibly) the current versions and description.   
  • Point out how the core data elements will aid interoperability and reuse of data. These are mentioned but it may be beneficial to connect the dots with the mandates for EHRs which will enable the secondary use of consistent data as the data elements are added. 

As outlined in the plan, the “draft action plan was developed primarily with federal agency input.” While federal agency input is essential, we encourage a continued emphasis on proactively engaging all sectors and stakeholders within the health IT and standards communities, including SDOs. Broadening the input will ensure that everyone has an active role in shaping and advancing this important initiative and could bring efficiencies if prior work is leveraged.

Submitted by:

Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN) and Piosoft (Filippo Napoli, PMP)

Overview timeline

Great effort to move interoperability over the years. 

FHIR Ecosystem

Comment

Include Health Care Clearinghouses as Partners

 

 

 

About the Cooperative Exchange

 

As representatives of the healthcare clearinghouse industry, we at The Cooperative Exchange are committed to promoting standardization and administrative simplification within the healthcare ecosystem. Our association comprises 23 member companies, collectively representing over 90% of the nation’s clearinghouse organizations. Together, we process over 6 billion healthcare claims annually, reflecting more than 2 trillion dollars in billed services.

The draft Federal FHIR Action Plan, in the section on Vision for 2026, sets out an ambitious vision for the Federal Government.  That vision talks about a number of entities in health care – patients, providers, plans, public health agencies.  However, the vision leaves out a key player – clearinghouses.  Our members play a key role in supporting both plans and providers in their interoperability pathway.

 

Cooperative Exchange’s Position on FHIR APIs

 

The Cooperative Exchange fully supports the goal of Fast Healthcare Interoperability Resources (FHIR). We believe that building reusable components that enable real-time transactions and bi-directional conversations between payers and providers at the point of care will improve the healthcare system. Our aim is to achieve this while minimizing industry burden.  We support implementing FHIR for administrative transactions that are not already working at scale and that are best suited to benefit from real-time data exchange, and then systematically updating currently scaled administrative transactions to FHIR as appropriate for each unique use case. We recommend that ASTP work with X12 as well as HL7 to develop FHIR administrative transactions for real-time data exchange.  X12’s vast experience within the administrative transaction space will be vital to ensuring the industry has FHIR standards that work in our current ecosystem. 

 

The Cooperative Exchange is interested in providing expertise to Federal Agencies in the business processes necessary to make FHIR-based exchanges successful. The following is how intermediaries, in partnership with the Cooperative Exchange, may be able to help implement FHIR at scale:

•            Many mid-size to small payers and providers have opted to use a technology partner to  create or maintain necessary connections to entities with which they exchange data. These organizations frequently cite a preference to outsource that expertise, gaining instant and streamlined access to many diverse connections rather than growing that network in house. While we realize that there will be diverse approaches to implementing the FHIR APIs, clearinghouses will continue to simplify the technical approach for both parties. We feel that as standards and models are developed for implementing FHIR, there should be equal consideration given to provider-to-clearinghouse-payer models as there currently is to provider-to-payer models.

•            FHIR implementation guides do not take into consideration intermediaries, which currently manage administrative traffic for provider and payer organizations, as a significant technology partner for providers and payers. As a stakeholder, we would like the opportunity to offer our recommendations to these guides. 

•            For years, intermediaries have been connecting to various systems and are familiar with the variability and challenges that come along with it. Considering that CMS has announced their plan to build an endpoint directory, we’d like to learn more and be a part of how this type of information is organized and communicated.

•            There is an opportunity to better illustrate how FHIR would operate in the real world, where systems would need to accommodate many-to-many connections concurrently. We propose a collaboration in which intermediaries can assist with building use cases and complex workflows to show successful data interchange through intermediaries.

We suggest that the plan include working with the Cooperative Exchange and our members to achieve its vision.

 

 

 

Public Health & Emergency Response Components

Here are the comments towards the 'Public Health & Emergency Response Components' that Washington State Department of Health recommends for consideration:

  • US Situational Awareness Framework for Reporting (SAFR) FHIR IG (currently under development):  The implementation guide is being developed as a framework for the US Situational Awareness capabilities during emergencies and is constrained from Situational Awareness for Novel Epidemic Response (SANER) FHIR IG. The SAFR FHIR IG is recommended to be used referencing to and interacting with the FHIR Measures computational libraries of situational awareness measures relevant to the profiles in the IG VIZ. currently 'Bed Capacity' and 'Hospital Respiratory Data' (HRD) profiles. 
  • Childhood development milestones assessment framework: Assessment and Long Term Follow UP (LTFU) of development milestone and hence recording delays in the milestones including those conditions listed in Newborn Screening, that are identified as caused due to metabolic and congenital etiologies are currently not included in the action plan. The assessment may be done with the use of FHIR Structured Data Capture (SDC) IG and harmonized with the Healthcare Surveys IG. 

Research Components

Its exciting to see on the roadmap for further development around research study data, including but not limited to cancer specific data. The third party vendors we exchange research data with from our healthcare EMR use legacy protocols with very limited functionality. It lacks the modularity available with FHIR resources leading to a clunky implementation for exchanging data. 

There has also been a need for custom development to exchange the needed cancer related data between software systems currently in use that we've been hoping could eventually be replaced by using FHIR/USCDI standards.

Standard / Specification: HL7® FHIR® Subscriptions R5 Backport

Continued development of this standard is promising and applauded, In current state with version R4 we don't see developers using this functionality but can see where it could provide the following benefits:

  • Improved Data Synchronization: By notifying requesting systems proactively about data changes, the system ensures that clinical data remains synchronized in real-time. This can lead to better decision-making and improved patient outcomes by providing accurate and up-to-date information when needed.
  • Reduced API Call Load: Implementing this subscription-based model could significantly reduce the need for repetitive API polling by requesting systems. This minimizes the strain on IT infrastructure, leading to more efficient use of resources and potentially lower operational costs.

Research Components

  1. Research would benefit from leveraging the volumes of great work done through the NIH NCI EVS team to curate and maintain controlled terminology for clinical research. This terminology was developed with the CDISC community and is required by FDA and Japan’s PMDA. This body of knowledge has been available since 2008 and has been growing each year, now supporting foundational research needs as well as over 50 therapeutic areas. The terminology was developed through a consensus-based process involving thousands of volunteers from a variety of different organizations around the world to supports research from protocol and data collection through data tabulation, analysis and reporting. These standards are harmonized globally to be synergistic.  It would save significant time and cost to start with this controlled terminology to support research with USCDI and US Core.
  2. Connecting previously defined data elements for research (as developed by the CDISC community) and their codes within the NCI EVS Metathesaurus to the healthcare coding systems, codes, and labels (aka healthcare terminology) will streamline the path to using FHIR and to achieving interoperability.
  3. In the “FHIR Ecosystem” web page, https://www.healthit.gov/isp/fhir-ecosystem, under the “Care Delivery and Engagement Component” gray bar, the first bullet under “IPS FHIR IG”, – mentions that the FHIR Resources are based on US Core FHIR IG that use well defined international terminologies. This is not correct. The IPS is based on the base FHIR specification (FHIR R4). The US would benefit from aligning the terminologies in the US Core IG to the IPS FHIR IG in addition to the IPA FHIR IG. SNOMED has a US based version. Would it be possible to use the SNOMED International version since this will facilitate global data exchange? There are LOINC codes in the US Core FHIR IG terminologies and many options to choose from for valuesets. In contrast, the IPS FHIR IG valuesets are narrower with specified code systems and codes that will enable data exchange without loss of meaning.  

                                         Aligning with IPS FHIR IG and IPA FHIR IG will enable global interoperability and sharing of health information to enable patient care and secondary use of data.  

  1. Currently the only documents mentioned in the draft Federal FHIR Action Plan are the mCode IG and the Genomics Reporting IG.  We recommend adding the following Vulcan FHIR IGs in support of research, there may be additional public health IGs that would be beneficial to highlight.  

Submitted by:
Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)
 

Public Health and Emergency Response Components

HL7 FHIR Electronic Case Reporting IG (eCR IG) is noted as pilot. There is an opportunity for leveraging these data elements to align case reports with the CDISC standards case report forms that are used in both public health and pharma trials by NIH centers, CROs, and researchers around the world. They are built into RedCap and OpenClinica, and the specifications are available on the CDISC website for other vendors to use. This would enable data aggregation more efficiently.  Such forms could be used with IHE RFD as mentioned previously.  CDISC has worked with NIH and others on standards for different Therapeutic Areas and sample case report forms have been provided for Ebola, Vaccines, Virology, COVID-19 and others including Oncology (various types of cancers), Asthma and Alzheimer’s and Parkinsons’ Diseases. The work was done through the Coalition For Accelerating Standards and Therapies (CFAST) with many different organizations and SMEs including CPath, FDA, NIH, CDISC, TransCelerate and Oxford. These standards and their terminology are required by FDA for submissions of data to support the approval of new therapies.  Why would these not be leveraged as a starting point to accelerate the development and adoption of FHIR for research?

Healthcare IT facilities must comply with both ethical and IT regulations. When exchanging data with external facilities, it is standard practice to disclose the security standards and procedures used to protect that data and to require the receiving party to adhere to the same basic standards for safeguarding patient information. This practice is legitimate, with the HIPAA BAA agreement serving as the typical framework for such stipulations. An End-User License Agreement (EULA) can be presented online to users, and their responses can be captured and stored electronically.

Submitted by:
Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)

Care Delivery and Engagement Components

The term "Information Blocking" refers to any interference with the access, exchange, or use of electronic health information, making it a broad and inclusive concept. Within the "Consequences and Enforcement" section, it notes the potential for "civil monetary penalties of up to $1 million per violation." A suggestion would be to implement a minimum penalty for first offenses to enhance deterrence for potential violators. For instance, penalties could be structured to begin at $5,000, escalating to a maximum of $1 million per violation, thereby reinforcing the seriousness of compliance from the outset. This stepwise payment structure for offences will help with the education process in the event of unintentional “information blocking” occurrences.

The primary concern regarding the ASTP's policing approach is whether it differentiates between users who are knowingly blocking information for nefarious reasons and those who are unintentionally unable to share data, such as in cases of technical defects that lead to APIs returning blank data. In both instances, the information is effectively blocked. However, without a clear definition of the active role played by users in intentionally blocking data access or sharing, addressing these issues downstream after a complaint has been filed may prove challenging. Additionally, the ASTP should establish reasonable and customary expectations on timeliness. An example is onboarding timelines related to EHR integration with third parties for data sharing, as delays in this process could also be viewed as a form of information blocking.

Submitted by:
Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)

Payment and Health Quality Components

Leveraging other standards work such as that done by ISO, IEEE, OMG, IHE, openEHR, and CDISC to solve the interoperability puzzle will make the work go faster. There has been work done in several spaces such as IHE RFD (used for any form to populate data from the EHR, including Quality data); this work could be updated to use FHIR, and the work can be connected and leveraged in each area for everyone’s benefit. Otherwise, completing this work anew will take substantially more time. Additionally, there are other beneficial HL7 standards still in use (such as CDA). Connecting these and having them fit together and providing the ability to go back and forth between the different data models will yield great benefits. In addition to these standards, the various data models such as OMOP, i2b2/ACT, CDISC SDTM provide another level or layer of data in a different view. See Figure 1 at the end of document. 

Recommend consistent data transformations used standardly to increase the data quality and enhance the data reusability strengthening the meaning and reliability of transformed data.

Submitted by:
Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)

Network Components

To address the challenges faced by API users in connecting with multiple healthcare providers, we propose the establishment of a centralized onboarding facility. This facility would streamline the process by onboarding new users, vetting them, and assigning unique IDs, thereby eliminating the need for individual API integrations with multiple EHR systems. By creating a single point of access, users would gain inherent connectivity to all approved EHRs. This centralized facility can be likened to a “Google Password Manager” service, acting as a secure and trusted gateway that provides API users, with a “single login”, access to a wide range of EHR systems through one seamless onboarding process, eliminating the current multiple login process.

Submitted by:
Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)

Core Components

Core Components

We applaud the efforts to leverage and harmonize the standards to benefit health and human services. The Action Plan states the FHIR standard will be essential, and we agree this is a good start. However, leveraging other available and applicable standards, particularly in the case of terminology, will move us all forward faster and perhaps better. Specifically, in the case of research standards, benefits and efficiencies have been proven over the past 25 years in a global research community, including NIH centers and FDA. These terminologies to support core data elements and data elements for over 50 therapeutic areas are mature and are maintained by NCI Enterprise Vocabulary Services. It is inefficient and will not enable interoperability to allow users a choice of terminologies.   To truly reach the goal in a reasonable timeframe, it will be important to leverage this past consensus-based work that is relevant to billions of patientsworldwide. Otherwise, it could very well take another 20 years to redo work that has already been done.

Submitted by:

Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)

Early-Stage Capabilities

Comment

Enhance data exchange between Public Health & Healthcare Orgs

Listed below are the two capabilities that are recommended for addition to the section 'Capability: Enhance and ease data exchange between public health institutions and provider organizations':

  • Development and use of a federated contact tracing system that could be used to pull data to the State systems and vice versa. This is an infrastructure that is needed for responding to localized, widespread, and multi-state epidemics.
  • Implementing FHIR at Scale Taskforce (FAST) IG including directory services and other use cases, as part of the federal infrastructure, for publishing the FHIR APIs and respective documentation for authentication/authorization, consent management etc.

FHIR Write

This capability is still in its early stages but holds significant promise for the future by enabling more seamless bidirectional integration between systems exchanging data with a FHIR server. Currently, when a bidirectional interface is needed, a hybrid approach is often required. For example, vendors might request healthcare data using FHIR while sending data back into the EMR via direct HL7 interfaces. FHIR write functionality could potentially eliminate the need for such hybrid solutions, depending on the types of data sets supported as a standard.

Public Health

HL7 FHIR Electronic Case Reporting IG (eCR IG) is noted as pilot. There is an opportunity for leveraging these data elements to align case reports with the CDISC standards case report forms that are used in both public health and pharma trials by NIH centers, CROs, and researchers around the world. They are built into RedCap and OpenClinica, and the specifications are available on the CDISC website for other vendors to use. This would enable data aggregation more efficiently.  Such forms could be used with IHE RFD as mentioned previously.  CDISC has worked with NIH and others on standards for different Therapeutic Areas and sample case report forms have been provided for Ebola, Vaccines, Virology, COVID-19 and others including Oncology (various types of cancers), Asthma and Alzheimer’s and Parkinsons’ Diseases. The work was done through the Coalition For Accelerating Standards and Therapies (CFAST) with many different organizations and SMEs including CPath, FDA, NIH, CDISC, TransCelerate and Oxford. These standards and their terminology are required by FDA for submissions of data to support the approval of new therapies.  Why would these not be leveraged as a starting point to accelerate the development and adoption of FHIR for research?

Submitted by:
Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)

Enhance and ease data exchange for research purposes

Research would benefit from leveraging the volumes of great work done through the NIH NCI EVS team to curate and maintain controlled terminology for clinical research. This terminology was developed with the CDISC community and is required by FDA and Japan’s PMDA. This body of knowledge has been available since 2008 and has been growing each year, now supporting foundational research needs as well as over 50 therapeutic areas. The terminology was developed through a consensus-based process involving thousands of volunteers from a variety of different organizations around the world to supports research from protocol and data collection through data tabulation, analysis and reporting. These standards are harmonized globally to be synergistic.  It would save significant time and cost to start with this controlled terminology to support research with USCDI and US Core.

Connecting previously defined data elements for research (as developed by the CDISC community) and their codes within the NCI EVS Metathesaurus to the healthcare coding systems, codes, and labels (aka healthcare terminology) will streamline the path to using FHIR and to achieving interoperability.

Currently the only documents mentioned in the draft Federal FHIR Action Plan are the mCode IG and the Genomics Reporting IG.  

We recommend adding the following FHIR IGs in support of research, there may be additional public health IGs that would be beneficial to highlight.  

We applaud the efforts to leverage and harmonize the standards to benefit health and human services. The Action Plan states the FHIR standard will be essential, and we agree this is a good start. However, leveraging other available and applicable standards, particularly in the case of terminology, will move us all forward faster and perhaps better. Specifically, in the case of research standards, benefits and efficiencies have been proven over the past 25 years in a global research community, including NIH centers and FDA. These terminologies to support core data elements and data elements for over 50 therapeutic areas are mature and are maintained by NCI Enterprise Vocabulary Services. It is inefficient and will not enable interoperability to allow users a choice of terminologies.   To truly reach the goal in a reasonable timeframe, it will be important to leverage this past consensus-based work that is relevant to billions of patients worldwide. Otherwise, it could very well take another 20 years to redo work that has already been done.

Submitted by:
Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)

Moving Forward

Comment

Federal Coordination

As outlined in the plan, the “draft action plan was developed primarily with federal agency input.” While federal agency input is essential, we encourage a continued emphasis on proactively engaging all sectors and stakeholders within the health IT and standards communities, including SDOs. Broadening the input will ensure that everyone has an active role in shaping and advancing this important initiative and could bring efficiencies if prior work is leveraged.

Submitted by:
Catalysis (Rebecca D. Kush, PhD), CDISC (Rebecca Baker, MS, MHA, BSN, RN), and Piosoft (Filippo Napoli, PMP)
 

UPDATES


Vocabulary/Code Set/Terminology

Allergies and Intolerances

Representing Patient Allergic Reactions

Comment

Testing comment for basic registered user

Testing only, please discard.

NCPDP Comments

NCPDP supports ONC’s recommendations.

NCPDP Comment

This comment should be applied universally across the 2020 ISA Reference Edition. All hyperlinks for the NCPDP Standards should be updated to reflect: https://standards.ncpdp.org/Access-to-Standards.aspx?

NCPDP Commnet

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Patient Allergic Reactions. The Allergy and Clinical Immunology CPT codes (95004 – 95199) identify patient assessment and intervention for allergy testing, ingestion challenge testing, and allergen immunotherapy.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

NCPDP Comment

NCPDP supports ONC’s recommendations.

Either or both value sets are large

Either or both value sets are large, establish a core commonly charted values list for implementation. Support outliers.

ONC response to comments

"Problem" VS extremely broad, recommend removal and suggest using "Adverse Clinical Reaction" and "Allergic and Intolerance Type" VSs as starter set.  Links added to VSAC.  Validation of comprehensiveness is difficult, although second VS is stewarded by HL7 Terminology workgroup.

Links to value sets

Links to value sets in VSAC, PHINVADS or elsewhere would be very helpful.  A URN or OID means NOTHING to about 98% of the affected parties.

The value sets are a start, but the first represents about 1/3 of all SNOMED CT codes. This is not a useful reduction to something that represents value to the community.

The second appears to be useful, but without a way to understand the process by which the codes were selected, it is difficult to validate it. That would require a rather deep analysis.  It would be helpful if VSAC value sets included something more than a one line description of the value set.  Without further information about the value set, and considering its source from a federal group rather than a standards organization, it is hard to judge whether this valueset is viable.

 

Representing Patient Allergies and Intolerances; Environmental Substances

Comment

NCPDP Comments

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Patient Allergies and Intolerances; Environmental Substances. The Allergy and Clinical Immunology CPT codes (95004 – 95199) identify patient assessment and intervention for allergy testing and allergen immunotherapy, including environmental substances.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

SNOMED CT value needs…

SNOMED CT value needs further restriction for Environmental Substances

UNII is really not all that helpful for clinical use.

Representing Patient Allergies and Intolerances; Food Substances

Comment

NCPDP Comments

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Patient Allergies and Intolerances; Food Substances. The Allergy and Clinical Immunology CPT codes (95004 – 95199) identify patient assessment and intervention for allergy testing, ingestion challenge testing, and allergen immunotherapy, including food substances.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

Should use the American Allergy and Immunology list

It is short (but longer than the one below), uncluttered by special forms of food and is authoritative. While any food can cause an adverse reaction, eight types of food account for about 90% of all reactions:

http://acaai.org/allergies/types/food-allergy

Eggs, Milk, Peanuts, Tree nuts, Fish, Shellfish, Wheat, Soy 

What is the state of UNII, its not listed

What is the state of UNII, its not listed? UNII has been problematic when implementing related to the volume of choices.  SNOMED has a similar issue.  Establish a top used list for Food Substances as core implementation list. Allow outliers where needed, this will improve implementation and interoperability.  

Food substances too broad

There are over 4000 of these codes in SNOMED CT. It is still way to broad to be useful. Would suggest that a value set that would be useful would cover top 100 food items.  Avoid repetition like

256349002 Peanut - dietary (substance)      
229889003 Peanut brittle (substance)      
102260001 Peanut butter (substance)      
412047006 Peanut containing products (substance)

 

How many different ways do we need to say an interpret Peanut containing products?  Would you feed peanuts to someone with a peanut butter allergy?  That kind of clinical decision making needs to go into the making of these value sets.

 

UNII code system and value set is specific to FDA Product labeling and is not all that helpful for clinical use.  SNOMED CT is much better suited for this purpose.

UNII has broad coverage and…

UNII has broad coverage and connections to many other code systems and to chemical structures. Also includes what food and/or allergens. Would not dismiss it out of hand.

Representing Patient Allergies and Intolerances; Medications

Comment

NCPDP Comments

  1. NCPDP recommends ONC add the National Drug Code (NDC). The NDC distinctly identifies the product and is critical for capturing specific drug allergies including active and inactive ingredients (e.g., dyes, flavorings) as well as reporting adverse drug events to the FDA. RxNorm does not identify the specific packaged product that was dispensed and would not be as useful in these situations.
  2. Add the following:

Type-Standard

Standard/Implementation Specification- National Drug Code (NDC)

Standards Process Maturity – Final

Implementation Maturity- Production

Adoption Level – 5

Federally Required – Yes

Cost – $

Test Tool Availability – N/A

NCPDP Comments

NCPDP supports ONC’s recommendations.

Tighten up the applicable starter sets

The various identified "starter value sets" in this section presents a confusing overlapping collection. The three items listed as "representing drug classes" are not equivalent and only the SNOMED CT (SCT) Product hierarchy is actually aligned with actual drug class concepts. SNOMED CT Drug product class concepts are uniquely valuable because NLM links SCT product class concepts to the appropriate RXNorm drug ingredients to support Drug class to RxNorm or even NDC codes identification via available APIs at RxClass. The other two suggested sets (Common Drug Classes for Allergy and Intolerance documentation and Common Drug Substances for Allergy and Intolerance documentation) do not represent useful drug classes and should not be listed in the Drug Classes for Allergy and Intolerance documentation section.

For the Representing Medication section, the listed set Clinical Drug Ingredient (2.16.840.1.113762.1.4.1010.7) (RxNorm ingredient codes) is a subset of all potential drug ingredient RxNorm codes that was based on a historical review of common drug ingredients listed as causes of allergy or intolerance in clinical records done a number of years ago. While this list has not been updated, it is useful. I suggest adding to the suggestions in this section the set you will remove from the "class" set as it is the list of every ingredient or related code type in RxNorm - over 25,000 codes. This is the Common Drug Substances for Allergy and Intolerance documentation (2.16.840.1.113762.1.4.1186.1) set.

NCPDP Commnet

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Patient Allergies and Intolerances; Medications. The Allergy and Clinical Immunology CPT codes (95004 – 95199) identify patient assessment and intervention for allergy testing, ingestion challenge testing, and allergen immunotherapy, including medications.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

NCPDP Comment

  1. Add the following:

Type-Implementation Specification

Standard Implementation/Specification- NCPDP SCRIPT Standard, Implementation Guide, Version 2017071

Standards Process Maturity – Final

Implementation Maturity- Production

Adoption Level – N/A

Federally Required – No

Cost – $

Test Tool Availability – Yes

Test Tool Link: https://tools.ncpdp.org/erx/#/home

 

  1. NCPDP SCRIPT Standard Version 2017071 allows for transmission of all the data sets.

Pharmacy HIT Collaborative's Comments on ONC's Proposed 2018 ISA

The Pharmacy HIT Collaborative supports using RxNorm and SNOMED CT; however, we ask for clarification as to why MED-RT (formerly NDF-RT) has been removed as a standard/implementation specification, as it was included in the final 2017 ISA and is currently included under “Representing Patient Medications.” We recommend that it be returned.   

Class Medication Allergen - Suggest SNOMED CT Substance Hierarch

Strong support SNOMED CT as replacement to NDF-RT which is no longer supported.  In past modeling, have recommended the "substance" domain in lieu of the listed "product" domain as the "class" substance contains relationships to related medication ingredient substances.  For example, current NDF-RT N0000011281 "Penicillins" spans RXCUI 7986 within RxNorm.  RXCUI 7986 also spans SNOMED CT 373270004 "Penicillin -class of antibiotic- (substance)," and 6369005 "Penicillin -class of antibiotic- (product)" - the "substance" value has links to the ingredient "children" that would be expected to span the class, such as "amoxicillin". The "product" hierarchy does not have a direct path to member "ingredient" based concepts.. instead, it links to a product concept such as "product containing amoxicillin".

Consider including MED-RT to represent classes of medications

MED-RT is an emerging standard that allows for representing classes of medications.  This has already been added under "Representing Patient Medications".  Shouldn't this also be added here for representing allergies to a class of medication? 

Biologics

Representing Biological Products

Comment

Clinical Notes

Representing Clinical Notes

Comment

NCPDP Comments

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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.

Representing Clinical Tests Ordered/Performed

Comment

Comment for Representing Non-imaging and Non-laboratory Clinical

Comment for Representing Non-imaging and Non-laboratory Clinical Tests

The American Medical Association requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Non-imaging and Non-laboratory Clinical Tests. The CPT code set contains numerous codes for non-imaging and non-laboratory clinical tests, including, but not limited to:

  • Electroencephalography (EEG)
  • Echocardiography (EKG)
  • Cardiovascular and exercise stress tests
  • Pulmonary function tests
  • Electromyography (EMG)
  • Electroretinography (ERG)
  • Audiologic function tests
  • Evoked potential tests
  • Intraocular pressure measurement
  • Visual acuity and function tests
  • Allergy challenge tests
  • Fetal monitoring
  • Sleep studies

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, laboratory, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

Representing Clinical Tests Result/Value

Comment

ACLA Comments on Representing Clinical Test Result/Value

American Clinical Laboratory Association Comment:
This new section is confusing because it appears to blend other use cases for Laboratory and Imaging tests as clinical testing.   Please clarify the intent.  

We recommend this statement be removed from Clinical Tests; Representing a Clinical Test Result/Value. Section and only include the Clinical Tests:  Representing Non-Laboratory and Non-Laboratory Clinical Tests.

Clinical Tests, like Laboratory and Diagnostic Imaging, should be represented by at least two components, the test, and the results. For Clinical Tests, these components are:
     • Clinical Test - The coded name of the non-imaging or non-laboratory test performed on a patient.
     • Clinical Test Result/Report - Interpreted results of clinical tests that may include study performed, reason, findings, and impressions. Includes both structured and unstructured (narrative) components.

 

Cognitive Status

Representing Patient Cognitive Status

Comment

The AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Patient Cognitive Status. The CPT code set contains Evaluation and Management code 99483, which identifies a comprehensive cognitive assessment and care planning for a patient with a known cognitive impairment.  The services performed include:

  • Cognition-focused evaluation with pertinent history and examination,
  • Functional assessment for ability to perform various activities and decision-making capacity,
  • Use of standardized tests for staging of dementia,
  • Medication review for high-risk medications,
  • Evaluation for neuropsychiatric and behavioral symptoms using standardized screening tests,
  • Evaluation of environmental safety,
  • Evaluation of caregivers and their knowledge, needs, and supports,
  • Development, revision, or review of a care plan,

 

While the LOINC codes that assess cognitive status and the FHIR use case used to support the exchange of functional and cognitive status assessment information are still in development, the CPT code 99483 is an adopted standard. The CPT code conveys the same or similar information as the LOINC codes for cognitive function (11333-2, 75275-8, and 11332-4), which is currently listed as a standard for this interoperability need.

 

 

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

NCPDP Comments

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Patient Cognitive Status. The CPT code set contains Evaluation and Management code 99483, which identifies a comprehensive cognitive assessment of the patient, including, but not limited to:

  • Cognition-focused evaluation,
  • Functional assessment, including decision-making capacity,
  • Use of standardized instruments for staging of dementia,
  • Evaluation of safety,
  • Identification of caregivers, and
  • Creation of a written care plan.

CPT codes 96105-96146 identify neuro-cognitive assessments and tests, including cognitive performance testing, interactive feedback, neurobehavioral status examination, and neuropsychological testing evaluation services.

Cognitive skills are also identified in the Occupational Therapy Evaluations codes, 97165 – 97167, and Therapeutic Procedures, 97129.

In addition, CPT Category II codes 3720F and 3755F identify assessment and screening for cognitive impairment or dysfunction within the treatment of other clinical conditions.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

COVID-19 Novel Coronavirus Pandemic

COVID-19 Novel Coronavirus Pandemic

Comment

NCPDP Comments

  1. NCPDP recommends adding reference to the NCPDP Emergency Preparedness Guidance document under the first bullet point in “Limitations, Dependencies, and Preconditions for Consideration”.
    1. NCPDP Emergency Preparedness Guidance document – NCPDP created guidance in response to the COVID-19 pandemic. This document provides guidance to the pharmacy industry for resources available during the pandemic. The intended audience is healthcare providers who would need resource information for assisting patients in accessing products and services provided by pharmacies during the pandemic. This information can be found in section 10 of the document and will be updated as new information is available.
    2. For details, refer to the NCPDP EMERGENCY PREPAREDNESS GUIDANCE document on the Resources page of the NCPDP website.

Adoption Level for HL7 2.5.1 IG

We believe the adoption level for the HL7 2.5.1 Implementation Guide for Immunization Messaging, Release 1.5 to be at a 5 for high or widespread adoption, given there are over 120,000 active HL7 interfaces exchanging immunization data using this standard (CDC 2020 IIS Annual Report). 

IG on Vocabulary Page

Given this page is focused on vocabulary, we recommend removing the HL7 IG 2.5.1 reference. If it stays, however, we believe it should reference the same HL7 IG 2.5.1 guide referenced on the ISA content page: www.healthit.gov/isa/exchanging-immunization-data-immunization-registries. 

Inclusion of IGs in the vocabulary list

It seems odd to include IG references in the list of vocabulary resources. After discussion with the HL7 Public Health Work Group, we recommend moving the IG references to the Content/Structure section (not that the immunization IG is already in that section).

SANER FHIR IG is an interoperability specification

We're not sure why the SANER FHIR IG is listed under terminology.  It's not a terminology IG but makes use of other terminology sets.  I would likely be better to be placed under Services/Exchange under Public Health.

WA State Department of Health SANER Comments

Washington State Department of Health fully supports the listing of the emerging standard Situational Awareness for Novel Epidemic Response (SANER). It is vital to ensuring public health and others can effectively monitor supplies, patient capacity and counts of patient’s being cared for during an outbreak or pandemic.

ACLA request to update content

Please revise both hyperlinks for Logica (https://covid-19-ig.logicahealth.org/index.html) to reference the official HL7 Logica webpage: http://hl7.org/standards/hsp-marketplace/index.html. The current ISA LOGICA hyperlink is to a non-HL7 website; HL7 projects must be hosted on an HL7 website per HL7 policy.

  • Justification statement: We believe HL7 will maintain their website supporting HL7 standards perpetually so an HL7.org hyperlink is preferable.

 

The SANER specification was published by HL7. Please update the hyperlink to the published version at: HL7 FHIR® Implementation Guide: Situational Awareness for Novel Epidemic Response (SANER) STU 1: http://hl7.org/fhir/uv/saner/STU1/

The current hyperlink is to HL7 FHIR’s ‘build’ environment which is preparatory to balloting and publication. (build.fhir.org/ig/HL7/fhir-saner/)

  • Justification statement: We believe HL7 will maintain their website supporting HL7 standards perpetually so an HL7.org hyperlink is preferable.

 

Please remove the June 4, 2020 date from the following reference: it has been updated twice since original publication:

CARES Act Section 18115 require laboratories to report results of SARS-CoV2 or COVID-19 testing to the Secretary of HHS in the form and manner outlined in this memo "COVID-19 Pandemic Response, Laboratory Data Reporting: CARES Act Section 18115 June 4, 2020"

 

 

WA State Department of Health SANER Comments

Washington State Department of Health fully supports the listing of the emerging standard Situational Awareness for Novel Epidemic Response (SANER). It is vital to ensuring public health and others can effectively monitor supplies, patient capacity and counts of patient’s being cared for during an outbreak or pandemic.

NCPDP Comments

  1. Request ONC to add NDC as a value where NDC is used.
  2. Add the following:

Type-Standard

Standard Implementation/Specification- National Drug Code (NDC)

Standards Process Maturity – Final

Implementation Maturity- Production

Adoption Level – 5

Federally Required – Yes

Cost – $

Test Tool Availability – N/A

  1. NCPDP Emergency Preparedness Guidance document - Declared emergencies, such as weather-related events (e.g., hurricanes, fires, floods, etc.), natural disasters (e.g., earthquakes) or pandemics (e.g., H1N1, COVID-19), have led NCPDP to create this document. This document provides guidance to the pharmacy industry for resources available during a declared emergency. The intended audience is healthcare providers who would need resource information for assisting patients in accessing their products and services provided by pharmacies during declared emergencies. This document will be updated as new information is available.

 

Additionally, this document addresses certain emergency preparedness processes and procedures that could be established as daily occurrences to be invoked at a moment’s notice, mitigating urgent training for emergency situations. For example:

        1. Payers/pharmacy benefit managers should have declared emergency criteria established within standard plan benefit templates.
        2. Pharmacy systems should support declared emergency plan billing rules and claim routing information as part of their normal procedures.
        3. Enrollment files and product history are routinely updated and should be accessible during a declared emergency.

 

For details, refer to the NCPDP EMERGENCY PREPAREDNESS GUIDANCE document on the Resources page of the NCPDP website.

Opportunity to Better Highlight the Specialty Care and Settings

HIMSS appreciates the addition of the new “Specialty Care and Settings” section of ISA, which includes information about COVID-19 needs.  However, it may be beneficial to find other approaches to highlight this section as an opportunity to help address the pandemic.  For example, when you click on the ISA Content tab, it does not include this new section.  We ask ONC to create a new tab for the “Interoperability for COVID-19 Novel Coronavirus Pandemic” Section that makes it more visible to ISA users.  Given the importance of federal guidance to respond to the pandemic, it seems like a missed opportunity to not highlight critical public health interoperability needs on COVID-19 in an easily accessible way.  As an initial step, ONC should also include an overview of this section and link on the main ISA webpage to enhance its overall visibility. 

We also ask that ONC consider “Telehealth/Remote Patient Monitoring” an additional specialty care/setting for inclusion in this section.  There is a growing need to consider data exchange for home settings and considerations around device interoperability.  There are a number of applications in use and this setting requires work across a number of systems (emergency medical services, hospital electronic health records, telemedicine system (synchronous and asynchronous) and, remote patient monitoring and device management).  ISA should provide guidance on specific standards to assist in exchange with this setting. 

In addition, HIMSS asks ONC to describe what the process is to determine inclusion in the Specialty Care and Setting section, including certain criteria that must be met.  A better overview of this section and how additional inclusions are determined would be beneficial and further highlight the information included there. 

Demographics

Representing Patient Contact Information for Telecommunications

Comment

NCPDP Comments

NCPDP supports ONC’s recommendations.

Representing Nutrition Assessment, Diagnosis, Interventions and Monitoring/Evaluation

Comment

The CPT Category II codes…

The CPT Category II codes are intended to be used in the quality measure sets for which they were developed and not independent of the measure set. The AMA asks ONC to remove the following bullet under “Applicable Value Set(s) and Starter Set(s)”:

  • CPT Category II  3759F and 3760F: identify assessment and screening for nutrition within the treatment of another clinical condition

The AMA requests that the…

The AMA requests that the following bullet under “Applicable Value Set(s) and Starter Set(s)” be deleted:

 

  • CPT Category II  3759F and 3760F: identify assessment and screening for nutrition within the treatment of another clinical condition

 

Use of CPT Category II codes are limited to the quality measures for which they were developed.

NCPDP Comments

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Nutrition Assessment, Diagnosis, Interventions and Monitoring/Evaluation. CPT codes 97802 – 97804 identify patient assessment and intervention of medical nutrition therapy.

In addition, CPT Category II codes 3759F and 3760F identify assessment and screening for nutrition within the treatment of another clinical condition.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

Emergency Medical Services

Representing Health Care Data for Emergency Medical Services

Comment

NCPDP Comment

  1. NCPDP recommends that ONC add NDC as a value since this identifier is used when Emergency Medication is being administered to a patient.
  2. NCPDP recommends that ONC add the following:

Type-Standard

Standard Implementation/Specification- National Drug Code (NDC)

Standards Process Maturity – Final

Implementation Maturity- Production

Adoption Level – 5

Federally Required – Yes

Cost – $

Test Tool Availability – N/A

Pharmacy HIT Collaborative (PHIT) comment

PHIT supports NCPDP’s recommendation that NDC should be added as a value for use when emergency medication is being administered, NDC be used.  This request was also made for the 2023 Edition.

NCPDP Comments

  1. When emergency medication is being administered, NDC could be used. NCPDP requests ONC add NDC as a value.
  2. Add the following:

Type-Standard

Standard/Implementation Specification- National Drug Code (NDC)

Standards Process Maturity – Final

Implementation Maturity- Production

Adoption Level – 5

Federally Required – Yes

Cost – $

Test Tool Availability – N/A

WA State Department of Health EMS Comments

Washington State Department of Health supports the listing of the National Emergency Medical Services Information System (NEMSIS) standards for EMS data and only has one recommended change at this time. Washington State Department of Health recommends adding NEMSIS 3.5 as an emerging standard for emergency medical services data exchange, with implementation having began in Summer 2022. NEMSIS standards are an important collector of data for EMS in various contexts including public health, quality assurance and traffic safety.

WA State Department of Health EMS Comments

Washington State Department of Health supports the listing of the National Emergency Medical Services Information System (NEMSIS) standards for EMS data and only has one recommended change at this time. Washington State Department of Health recommends adding NEMSIS 3.5 as an emerging standard for emergency medical services data exchange as it likely could start being used in Spring of 2022. NEMSIS standards are an important collector of data for EMS in various contexts including public health, quality assurance and traffic safety.

NCPDP Comments

  1. When Emergency Medication is being administered, NDC and RxNorm could be used. Request ONC to add NDC and RxNorm as a value.
  2. Add the following:

Type-Standard

Standard Implementation/Specification- National Drug Code (NDC)

Standards Process Maturity – Final

Implementation Maturity- Production

Adoption Level – 5

Federally Required – Yes

Cost – $

Test Tool Availability – N/A

  1. Add the following:

Type-Standard

Standard Implementation/Specification- RxNorm

Standards Process Maturity – Final

Implementation Maturity- Production

Adoption Level – 4

Federally Required – Yes

Cost – Free

Test Tool Availability – N/A

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, allergies, medications, vaccinations, assessments, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Health Care Data for Emergency Medical Services. CPT codes 99281 – 99285 identify patient evaluation, examination, and medical decision making for emergency department services. CPT code 99288 identifies the direction of emergency care to emergency medical services personnel by a physician or other qualified health care professional.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

Regenstrief - Comment

We concur that the NEMSIS data set is an important collector of variables in the EMS context. In addition, we note that LOINC contains terms for observations and observation values for the complete NEMSIS data set (see panel 84428-2). Additionally, HL7 has developed the HL7 Version 3 Implementation Guide for CDA Release 2 - Level 3: Emergency Medical Services; Patient Care Report, Release 2 - US Realm, which uses the LOINC observation and observation values codes. http://www.hl7.org/implement/standards/product_brief.cfm?product_id=438

Further, it may also be worth mentioning that there is correlation between the NEMSIS (pre-hospital) data elements and the National Trauma Data Bank (NTDB) data dictionary, with the idea that the trauma registry could be “auto-populated” with the subset of relevant prehospital data. The National Trauma Data Standard data dictionary (2018 version) is also represented in LOINC (see panel 87825-6). HL7 has developed the HL7 CDA® R2 Implementation Guide: Trauma Registry Data Submission, Release 1 - US Realm, which uses LOINC. http://www.hl7.org/implement/standards/product_brief.cfm?product_id=355.

Last, the German Interdisciplinary Association of Intensive Care and Emergency Care Medicine defined a data set to enable efficient exchange from EMS pre-hospital services to receiving institutions. This complete data set of variables in the rescue service protocols are represented in LOINC (see panel 88677-0). This further supports the use of LOINC as a code system for use in this context.

Encounter Diagnosis, Assessment and Plan

Representing Assessment and Plan of Treatment

Comment

Current Procedural Terminology (CPT) code set be added

The American Medical Association (AMA) requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Assessment and Plan of Treatment. Currently LOINC and SNOMED CT are listed as standards for this interoperability need with no explanation about which codes to consider or how they are used to identify a patient’s assessment and plan of treatment.

 

The CPT Evaluation and Management codes communicate to other providers that the assessment and plan of treatment have been completed on a patient, as well as specific clinical information about the assessment, plan, and setting in which the assessment occurred. The complexity of the patient assessment, data analyzed, and patient management are conveyed in these codes. They support continuity of care for the patient throughout their health care journey. They also support the requirement for hospitals to share Admit, Discharge and Transfer data to improve patients’ transitions of care. In addition to the CPT Evaluation and Management codes that capture assessment and plan of treatment for individual encounters, additional CPT codes address the unique considerations in assessments and treatment plans across broader care episodes, such as Case Management Services – Medical Team Conferences, Care Plan Oversight Services, Cognitive Assessment and Care Plan Services, Care Management Services, and Psychiatric Collaborative Care Management Services. 

 

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders.

The AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Assessment and Plan of Treatment. This request was made in 2020 during which time the CPT code set was added and then removed.

 

The CPT Evaluation and Management codes specifically address multiple categories and subcategories for the broad range and levels of assessing and treatment planning for the patient, including:

  • Office or other outpatient services
  • Hospital observation services
  • Hospital inpatient services
  • Consultations
  • Emergency department services
  • Critical care services
  • Nursing facility services
  • Domiciliary, rest home, or custodial care
  • Home services
  • Case management services
  • Non-face-to-face services

 

The CPT codes convey the types of information that is required to alert providers and will empower them to proactively monitor their patients throughout the care continuum, improving patient outcomes and enhancing care continuity, while reducing preventable readmissions. In addition, the need for hospitals to share Admit, Discharge and Transfer data throughout the care community is critical, and now required, from improving interoperability and transitions of care for patients. These types of alerts to providers will empower them to proactively monitor their patients throughout the entire continuum of care, significantly improving patient outcomes and care continuity, while reducing preventable readmissions.

 

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

NCPDP Comments

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Assessment and Plan of Treatment. The CPT Evaluation and Management codes specifically address multiple categories and subcategories for the broad range and levels of assessing and planning treatment for the patient.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

Representing Patient Dental Encounter Diagnosis

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, allergies, medications, vaccinations, assessments, 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 and determine/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.

SNODENT free cost?

per link to snodent - the entry 'free' in cost is incorrect.

 

See the text on the website.

SNODENT is owned, maintained and distributed by the American Dental Association (ADA). The SNODENT code set is available under license at no cost for non commercial use. The license agreement terms also permit licensees to use SNODENT in the development of non-commercial, academic, scholarly articles and presentations for publication. For inquires about SNODENT licenses, use the contact information below.

 

 

Consider describing the license details in the preconditions section.

Representing Patient Medical Encounter Diagnosis

Comment

NCPDP Comments

NCPDP supports ONC’s recommendations.

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, allergies, medications, vaccinations, assessments, 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 and determine/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

While use of ICD-10 is limited, when transmitting diagnosis information it is required. HIPAA mandates the use of ICD-10 for pharmacy claims using NCPDP standards. SNOMED is optional. Adoption level for ICD-10 for the pharmacy is 5.

Family Health History

Representing Patient Family Health History

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, 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 and determine/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 AMA requests that the…

The AMA requests that the Current Procedural Terminology (CPT) code set be added to the standards listed in Section I: Representing Patient Family Health History. The CPT Evaluation and Management codes specifically address capturing the patient’s family health history. The E/M codes specifically provide information about:

  • The health status or cause of death of parents, siblings, and children;
  • Specific diseases related to problems identified in the chief complaint or history of the present illness, and/or system review
  • Diseases of family members that may be hereditary or place the patient at risk

Also, CPT code 96040 identifies medical genetics and genetic counseling services.

CPT is a comprehensive and regularly curated uniform language that accurately describes medical, surgical, and diagnostic services and provides for reliable communication among users. It has an extremely robust and mature development process with open and transparent meetings and clinical input from national medical specialties and relevant stakeholders. It is the most widely adopted outpatient procedure code set. Use of the CPT code set is federally required under HIPAA.

Wrong code system referenced for Problem Type

2.16.840.1.113883.3.88.12.3221.7.2 - this code system is not LOINC as referenced above...it is SNOMED.

feedback

Consider adding the following info to starter set

OMOP common data model is using SNOMED CT concepts (descendants of SNOMED CT term 125677006 (http://snomed.info/id/125677006))  to standardize family relationships (reference: https://github.com/OHDSI/CommonDataModel/wiki/FACT_RELATIONSHIP#conventions  ). 

Standard for observation…

Standard for observation values: should probably be Standard for observation values that are represented as codes (won't apply if they are free text or numbers).

Many of the details of Family Genomic History are not capturable by SNOMED CT. They will require the code systems provided by NCBI such as ClinVar, dbSNP, etc.

This is a greatly exaggerated assessment in the CMS Assessments. A large provider of IHE interfaces see SNOMED CT codes for 5% or fewer variables with multiple choice answers. Most are either text and/or local codes. 

Are the value sets in ISA accounting for the decisions and imple

  • Personal Relationship Role Type”  Personal Relationship Role Type urn:oid:2.16.840.1.113883.1.11.19563
  • There is a discrepancy between this value set and FHIR 4.0.  More generally are the value sets in ISA accounting for the decisions and implementations being made with FHIR?
    • Definition:          
      • A relationship between two people characterizing their "familial" relationship
      • OID:       2.16.840.1.113883.1.11.19579 (for OID based terminology systems)
    • Title:      V3 Value SetFamilyMember
    • Name:  v3.FamilyMember
    • Defining URL:     http://terminology.hl7.org/ValueSet/v3-FamilyMember

NCBI genomic data resources

NCBI resources for sequences, including RefSeq, dbVar, and dbSNP,  can be found here:

https://www.ncbi.nlm.nih.gov/guide/all/

Need code system for family…

Need code system for family relationships, SNOMED CT and HL7 V3 Personal Relationship have good value sets for this.

Functional Status/Disability

Representing Patient Functional Status and/or Disability

Comment