Toggle comment Display

ISA Single page with Comment


This file is created on 2024-09-11 07:02:44pm

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

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

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. 

 

 

EHR Association Comments on 2023 SVAP

On behalf of our nearly 30 member companies, the HIMSS Electronic Health Record (EHR) Association appreciates the opportunity to provide feedback to the ONC on the 2023 Standards Version Advancement Process (SVAP).

Our comments are attached in full.

EHR Association Comments to ONC on 2023 SVAP.pdf

USCDI

United States Core Data for Interoperability (USCDI)

The United States Core Data for Interoperability (USCDI) is a standardized set of health data classes and constituent data elements for nationwide, interoperable health information exchange. Review the USCDI Fact Sheet to learn more.

A USCDI Data Class is an aggregation of Data Elements by a common theme or use case.

A USCDI Data Element is a piece of data defined in USCDI for access, exchange or use of electronic health information.  

USCDI ONC New Data Element & Class (ONDEC) Submission System

USCDI V1

Please reference the USCDI version 1 document to the left for applicable standards versions associated with USCDI v1.

Harmful or undesired physiological responses associated with exposure to a substance.

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

Information about a person who participates or is expected to participate in the care of a patient.

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. 

Desired state to be achieved by a patient.

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.

Record of vaccine administration.

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

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

Condition, diagnosis, or reason for seeking medical attention.

Activity performed for or on a patient as part of the provision of care.

The metadata, or extra information about data, regarding who created the data and when it was created.

Representing a patient’s smoking behavior.

USCDI V2

The USCDI v2 contains data classes and elements from USCDI v1 and new data classes and elements submitted through the ONDEC system. Please reference the USCDI Version 2 document to the left for applicable vocabulary standards versions associated with USCDI v2 and to the ONC Standards Bulletin 21-3 for more information about the process to develop USCDI v2 and future versions.

Harmful or undesired physiological responses associated with exposure to a substance.

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

Information about a person who participates or is expected to participate in the care of a patient.

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. 

Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.

Tests that result in visual images requiring interpretation by a credentialed professional.

Information related to interactions between healthcare providers and a patient.

Desired state to be achieved by a patient.

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.

Record of vaccine administration.

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

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

Condition, diagnosis, or reason for seeking medical attention.

Activity performed for or on a patient as part of the provision of care.

The metadata, or extra information about data, regarding who created the data and when it was created.

Representing a patient’s smoking behavior.

USCDI V3

USCDI v3 contains data classes and elements from USCDI v2 and new data classes and elements submitted through the ONDEC system. Please reference the USCDI Version 3 document to the left for applicable vocabulary standards versions associated with USCDI v3 and to the ONC Standards Bulletin 22-2 for more information about the process to develop USCDI v3 and future versions.

Harmful or undesired physiological responses associated with exposure to a substance.

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

Information about a person who participates or is expected to participate in the care of a patient.

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. 

Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.

Tests that result in visual images requiring interpretation by a credentialed professional.

Information related to interactions between healthcare providers and a patient.

Desired state to be achieved by a patient.

Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.

Record of vaccine administration.

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

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

Condition, diagnosis, or reason for seeking medical attention.

Activity performed for or on a patient as part of the provision of care.

The metadata, or extra information about data, regarding who created the data and when it was created.

USCDI V4

USCDI v4 added 20 data elements and one data class to USCDI v3. Please reference the USCDI v4 standard document and the ONC Standards Bulletin 23-2 for details. To review the prioritization criteria ONC used to select the USCDI v4 data elements, refer to the ONC Standards Bulletin 22-2.

Harmful or undesired physiological responses associated with exposure to a substance.

Information about a person who participates or is expected to participate in the care of a patient.

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. 

Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.

Tests that result in visual images requiring interpretation by a credentialed professional.

Information related to interactions between healthcare providers and a patient.

Physical place of available services or resources.

Desired state to be achieved by a person or a person’s elections to guide care.

Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.

Record of vaccine administration.

An instrument, machine, appliance, implant, software or other article intended to be used for a medical purpose.

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

Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.

Condition, diagnosis, or reason for seeking medical attention.

Activity performed for or on a patient as part of the provision of care.

The metadata, or extra information about data, regarding who created the data and when it was created.

USCDI V5

USCDI v5 includes 16 new data elements and two new data classes. Please read the USCDI v5 standard document and the ONC Standards Bulletin 24-2 for details. The ONC New Data Element and Class (ONDEC) submission system is accepting recommendations for new data elements to be considered for Version 6. ONC also encourages the community to comment on previously submitted data elements not included in USCDI v5. ONC will consider all submissions and comments received by Monday, September 30, 2024, at 11:59 pm ET for USCDI v6.

Harmful or undesired physiological responses associated with exposure to a substance.

Information about a person who participates or is expected to participate in the care of a patient.

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. 

Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.

Tests that result in visual images requiring interpretation by a credentialed professional.

Information related to interactions between healthcare providers and a patient.

Physical place of available services or resources.

Desired state to be achieved by a person or a person’s elections to guide care.

Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.

Record of vaccine administration.

An instrument, machine, appliance, implant, software or other article intended to be used for a medical purpose.

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

Findings or other clinical data collected about a patient during care.

Provider-authored directive for the delivery of patient care services.

Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.

Condition, diagnosis, or reason for seeking medical attention.

Activity performed for or on a patient as part of the provision of care.

The metadata, or extra information about data, regarding who created the data and when it was created.

Level 2 data elements meet the following criteria:
  • Represented by a terminology standard or SDO-balloted technical specification or implementation guide.
  • Data element is captured, stored, or accessed in multiple production EHRs or other HIT modules from more than one developer.
  • Data element is electronically exchanged between more than two production EHRs or other HIT modules of different developers using available interoperability standards.
  • Use cases apply to most care settings or specialties.

Level 2

Harmful or undesired physiological responses associated with exposure to a substance.

Material substance originating from a biological entity intended to be transplanted or infused into another (possibly the same) biological entity.

Tests that result in visual images requiring interpretation by a credentialed professional.

Data related to an individual’s insurance coverage for health care.

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

Provider-authored directive for the delivery of patient care services.

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

Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.

Condition, diagnosis, or reason for seeking medical attention.

Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.

Level 1 data elements meet the following criteria:
  • Represented by a terminology standard or SDO-balloted technical specification or implementation guide.
  • Data element is captured, stored, or accessed in at least one production EHR or HIT module.
  • Data element is electronically exchanged between two production EHRs or other HIT modules using available interoperability standards.
  • Use cases apply to several care settings or specialties.

Level 1

Material substance originating from a biological entity intended to be transplanted or infused into another (possibly the same) biological entity.

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. 

Physical place of available services or resources.

Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.

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

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

The metadata, or extra information about data, regarding who created the data and when it was created.

Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.

Level 0 data elements meet the following criteria:
  • Not represented by a terminology standard or SDO-balloted technical specification or implementation guide.
  • Data element is captured, stored, or accessed in limited settings such as a pilot or proof of concept demonstration.
  • Data element is electronically exchanged in limited environments, such as connectathons or pilots.
  • Use cases apply to a limited number of care settings or specialties, or data element represents a specialization of other, more general data elements.

Level 0

Harmful or undesired physiological responses associated with exposure to a substance.

Material substance originating from a biological entity intended to be transplanted or infused into another (possibly the same) biological entity.

Information about a person who participates or is expected to participate in the care of a patient.

Tests that result in visual images requiring interpretation by a credentialed professional.

Desired state to be achieved by a patient.

Desired state to be achieved by a person or a person’s elections to guide care.

Data related to an individual’s insurance coverage for health care.

Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.

Condition, diagnosis, or reason for seeking medical attention.

The metadata, or extra information about data, regarding who created the data and when it was created.

Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.

 

Previous USCDI Versions

The USCDI ONC New Data Element and Class (ONDEC) Submission System supports a predictable, transparent, and collaborative process, allowing health IT stakeholders to submit new data elements and classes for future versions of USCDI. Click here for more information and to submit new data elements.

The USCDI standard will follow the Standards Version Advancement Process described in the Cures rule to allow health IT developers to update their systems to newer version of USCDI and provide these updates to their customers.

Comment

Human Rights Campaign Comments on Draft USCDI v5

A .pdf copy of the comments below with inline footnotes is available here (https://drive.google.com/file/d/1whiZLltgklFP1BcyPKIenxeO-SagIJJn/view). Thank you.

------------

On behalf of the Human Rights Campaign’s more than three million members and supporters nationwide, we write to offer our support for Draft Version 5 of the United States Core Data for Interoperability (“Draft USCDI v5”), which was recently made available for public comment by the Office of the National Coordinator for Health Information Technology (ONC).

The Human Rights Campaign (HRC) is America’s largest civil rights organization working to achieve lesbian, gay, bisexual, transgender, and queer (LGBTQ+) equality. By inspiring and engaging all Americans, HRC strives to end discrimination against LGBTQ+ citizens and realize a nation that achieves fundamental fairness and equality for allAs advocates for LGBTQ+ individuals, we believe that all people—including LGBTQ+ people—deserve to be able to meaningfully access medical care. Likewise, we believe that more reliable, quality data that allow for disaggregation by sexual orientation, gender identity, variations in sex characteristics, race, ethnicity, disability, age, and other key demographic variables are needed so we can better understand and support those living at the intersections of multiple marginalized identities. 

Unfortunately, we are currently living through a state of emergency wherein various forms of essential, life-saving care and services for transgender and other LGBTQ+ populations are being increasingly restricted and even criminalized at the state levelWe therefore commend ONC for its Draft USCDI v5, which mandates the collection of various data elements that providers must be able to exchange and which we believe will allow LGBTQ+ patients to transfer their care more easily to other providers as necessitated by these shifts in law and policy. Likewise, we believe that data collected consistent with these proposed data elements will generate valuable insights on the health and well-being of LGBTQ+ patients that could in turn inform providers’ efforts to improve equity among those populations. We therefore write to express our support for same being finalized as soon as possible.

Research on LGBTQ+ People and Their Health Outcomes

LGBTQ+ people are a growing population in the United States, living in every state and county and reflecting the breadth of diversity and lived experiences of the communities in which they liveUsing data collected through the U.S. Census Bureau’s Household Pulse Survey, we have previously estimated that at least 20 million adults in the U.S. identify as LGBTQ+.[1] Consistent with others’ research, we have also found that younger people are more likely than older people to identify as LGBTQ+.[2] Some researchers estimate that the population of LGBTQ+ adults in the U.S. over the age of 50 will double to over 5 million adults by 2030.[3] 

LGBTQ+ people in the U.S. are a demographically diverse population, with the Williams Institute using Gallup Daily Tracking survey data from 2012–2017 to estimate that 58% of LGBT adults identify as female.[4] Likewise, they found that 42% of LGBT adults identify among communities of color, including 1% that identify as American Indian and Alaska Native.[5] The Williams Institute also recently reported on evidence that individuals belonging to certain communities of color appear more likely than their White counterparts to identify as transgender.[6]

Studies have long documented persistent negative health outcomes among LGBTQ+ populations, including disparities in their physical and mental health when compared to their non-LGBTQ+ counterparts.[7] For example, data from the Centers for Disease Control and Prevention’s Behavioral Risk Factor Surveillance System indicate that LGBTQ+ adults, and transgender adults in particular, are significantly more likely than non-LGBTQ+ adults to self-report having at least one disability.[8] LGBTQ+ people of color often fare worse than their White and non-LGBTQ counterparts on several aspects of their health and related measures of well-being.[9] Likewise, the burden of observed negative health outcomes is not evenly distributed among LGBTQ+ communities, with transgender people in particular often reporting poorer health when compared to their cisgender counterparts,[10] and even when compared to cisgender LGB people.[11]

Research has also long indicated that LGBTQ+ populations face heightened challenges with respect to various determinants of their health—such as their being significantly more likely to be living in poverty than their straight and cisgender counterparts.[12] Such experiences can have continued impacts on their health and well-being well into the life course, as reflected by research on LGBTQ+ older adults reporting facing heightened and even unique challenges while aging when compared to their cisgender, heterosexual counterparts.[13] These negative health outcomes observed among LGBTQ+ populations have been linked to a number of factors, including exposure to minority stress due to experiences with stigma and discrimination.[14]

The Current State of Emergency for LGBTQ+ People Supports the Proposed Data Elements

Certain LGBTQ+ subpopulations report distinct needs tied to their health, like gender dysphoria—which is a health condition that disproportionately affects transgender people and is often treated via the provision of gender-affirming care.[15] Not all transgender and other gender-diverse people desiring the broad range of medical and non-medical interventions that comprise gender-affirming care seek it out for a variety of reasonsThese often and increasingly include the risk of being denied services and other forms of discrimination that evidence shows can even come at the hands of medical providers.[16] Indeed, research indicates that encountering discrimination while in pursuit of health care has long been an acute fear for and lived experience of transgender and other LGBTQ+ people.[17]

Discrimination against LGBTQ+ communities can take many forms and become insidiously commonplace for those holding multiple marginalized identities experiencing the combined brunt of ableism, racism, colorism, misogyny, and other forms of hateAnd unfortunately, such hatred against LGBTQ+ people is currently on the rise. Recently, and for the first time in our nearly half-century history, HRC declared a national state of emergency for LGBTQ+ people in the U.S., following an unprecedented spike in anti-LGBTQ+ legislative assaults, political extremism, and violent attacks nationwide.[18] In many parts of the country, LGBTQ+ people are facing efforts to roll back safeguards against discrimination and harassment alongside bills and administrative actions that would ban their access to critical services like gender-affirming care. 

LGBTQ+ people are being increasingly forced to seek services from new and alternative providers due to these bans, and some have even had to move their care to providers in different, less restrictive states. As this becomes a reality for more LGBTQ+ people, it is imperative that their various providers be able to exchange data that will ensure continuity of care and help facilitate improvement of services for these and other marginalized populations. We believe that the data elements proposed as part of the Draft USCDI v5 would allow for same and therefore support ONC finalizing this proposal as soon as possible. 

The Proposed Data Elements Would Empower Efforts to Increase Equity for LGBTQ+ Patients

Additionally, we believe that the Draft USCDI v5 data elements would have practical utility by empowering the government and providers’ efforts to advance equity for LGBTQI+ people. Information like a patient’s sexual orientation, gender identity, sex assigned at birth, name used, and pronouns are necessary for providers to be able to truly provide culturally affirming and responsive health care to their patients. We commend the Biden Administration for consistently recognizing this, and for those values being operationalized through ONC’s proposed Draft UCSDI v5. 

In June 2022, President Biden issued Executive Order 14075, which requires the creation of an evidence agenda to coordinate a cross-government effort to promote and engage in inclusive and responsible data collection practices on sexual orientation, gender identity, and variations in sex characteristics.[19] In January 2023, the Subcommittee on Sexual Orientation, Gender Identity, and Variations in Sex Characteristics Subcommittee on Equitable Data of the National Science and Technology Council published that Federal Evidence Agenda on LGBTQI+ Equity, which serves as a roadmap to drive federal agencies working to build evidence and leverage data to advance equity for LGBTQI+ people.[20] As summarized in that agenda, the executive order “recognizes that in order to advance equity for LGBTQI+ people, the Federal Government must continue to gather the evidence needed to understand the LGBTQI+ community, the barriers they face, and the policy changes the Federal Government can make to enable their health and well-being.”[21]

As part of these efforts to improve equity, we commend ONC for its inclusion of brand-new data elements on patients’ Pronouns and Name to Use within the Draft USCDI v5. One barrier to continued access to care faced by LGBTQ+ and non-LGBTQ+ people alike is not feeling safe and affirmed by one’s provider, specifically the risk of being referred to in an improper or disrespectful way. Individuals may wish to be referred to using names beyond their legal names for a variety of reasons and deserve to have that wish respected no matter the reason. This is particularly the case for LGBTQ+ patients facing an increasingly intolerant landscape across the country that can often find solace through providers willing to affirm their identities and lived experiences using a specific name or pronoun.

Fortunately, if the Draft USCDI v5 were to be finalized, providers will be able to empower one another to refer to even their newest patients just as they wish to be referred to. This would be the case even for those not already practicing inclusivity in this respect and could help drive providers to implement these and related practices. In this spirit, ONC should consider requiring a banner or pop up of some sort to ensure providers will see this information when opening patient records and therefore minimize the risk of an incorrect name being used to refer to a patient.

The Proposed Data Elements Are Consistent with Best Practices for Data Collection from LGBTQ+ People

Finally, we note that the government has long been collecting information on LGBTQ+ people,[22] with those experiences informing the proposed data elements ONC proposes here. Considering past successes by various federal agencies in this regard, we believe that providers will be able to successfully collect sexual orientation and gender identity-related information from patients themselves following the finalization of the Draft USCDI v5.

For decades, government and other researchers have researched concepts like sexual orientation and gender identity (SOGI), and found that it is more than possible to measure them and obtain quality data; and likewise that respondents do not find this information to be so sensitive that they would not provide it.[23] In a recent report on the collection of SOGI information in the survey context, the Office of Management and Budget (OMB) highlighted guiding principles that have emerged out of that work to support the ongoing collection of SOGI information, including that collected data should have utility, be in support of an agency’s mission, and be done with emphasis on protecting respondents’ confidentiality.[24] Recent recommendations issued by a panel formed by the National Academies of Sciences, Engineering, and Medicine on SOGI measurement in federal surveys and other instruments (the “NASEM Panel”) include well-tested measures for both sexual orientation and gender identity and echo OMB’s recommendations.[25]

Among other recommendations, the NASEM Panel recommends that agencies shift away from collecting information on sex unless information on that construct as a biological variable is necessary.[26] When that type of collection is in fact necessary, the NASEM Panel recommends that such collection “be accompanied by collection of data on gender,”[27] echoing OMB’s recommendation that “respondents should not be asked to provide their sex assigned at birth unless they are also given the opportunity to provide their current gender identity.”[28]We therefore commend the Draft USCDI v5 for being consistent with these recommendations, specifically through its inclusion of a new data element on Sex Parameter for Clinical Use alongside maintained data elements on Sexual Orientation and Gender Identity.

Resources like the Human Rights Campaign Foundation’s annual Healthcare Equality Index have been developed to provide information on and encourage facilities to adopt equitable, knowledgeable, sensitive, and welcoming health care practices free from stigma and discrimination for LGBTQ+ people.[29] This includes resources on the collection of SOGI information that we believe will help providers implement the requirements of the Draft USCDI v5 if they are to be finalized. Indeed, our analysis has found that approximately 90% of participants in our most recent index are already collecting these data, including patients’ sexual orientation, gender identity, name to use, and pronouns.

Finally, however, we note that included among the NASEM Panel’s recommendations is a call for more research on intersex people, or individuals with innate variations in their physical sex characteristics, which are not reflected within the Draft USCDI v5. Intersex people are estimated to make up as many as 1.7% of the global population.[30] Intersex and LGBTQ+ people share common, underserved health and equity needs, as well as challenges and experiences with social stigma, invisibility, and discrimination, that are rooted in restrictive norms and stereotypes regarding gender and sexual orientation. Intersex people also considerably overlap with other LGBTQI+ populations, though they are distinct.[31] For example, intersex populations are distinct from transgender and non-binary populations, but overall are more likely to be transgender or non-binary. Because of these overlapping challenges, we recommend that ONC continue working to ensure providers can be empowered to collect data on the intersex status of their patients alongside their sexual orientation and gender identity.

Thank you for this opportunity to submit comments in support of the health and well-being of LGBTQ+ people.

 

[1] Human Rights Campaign Found., We Are Here: Understanding The Size of the LGBTQ+ Community (2021), https://hrc-prod-requests.s3-us-west-2.amazonaws.com/We-Are-Here-120821.pdf

[2] Shoshana K. Goldberg et al., Human Rights Campaign & Bowling Green State Univ., Equality Electorate: The Projected Growth of the LGBTQ+ Voting Bloc in Coming Years (2022), https://hrc-prod-requests.s3-us-west-2.amazonaws.com/LGBTQ-VEP-Oct-2022.pdf. The Williams Institute has previously estimated that at least 2 million youth ages 13–17 identify as LGBT in the U.S., including approximately 300,000 youth who are transgender. See generally id.; Kerith J. Conron, Williams Inst., LGBT Youth Population in the United States (2020), https://williamsinstitute.law.ucla.edu/wp-content/uploads/LGBT-Youth-US-Pop-Sep-2020.pdf.

[3] Soon Kyu Choi & Ilan H. Meyer, Williams Inst., LGBT Aging: A Review Of Research Findings, Needs, And Policy Implications 2 (2016), https://williamsinstitute.law.ucla.edu/wp-content/uploads/LGBT-Aging-Aug-2016.pdf.

[4] LGBT Demographic Data Interactive, Williams Inst. (January 2019), https://williamsinstitute.law.ucla.edu/visualization/lgbt-stats/?topic=LGBT#demographic.

[5] Id.

[6] Jody L. Herman et al., Williams Inst., How Many Adults and Youth Identify as Transgender in the United States? 6 (2022), https://williamsinstitute.law.ucla.edu/wp-content/uploads/Trans-Pop-Update-Jun-2022.pdf;

[7] See, e.g., Kellan E. Baker, Findings From the Behavioral Risk Factor Surveillance System on Health-Related Quality of Life Among US Transgender Adults, 2014-2017, 179 JAMA Internal Medicine 1141 (2019), https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2730765; Gilbert Gonzales & Carrie Henning-Smith, Health Disparities by Sexual Orientation: Results and Implications from the Behavioral Risk Factor Surveillance System, 42 J. Community Health 1163 (2017), https://pubmed.ncbi.nlm.nih.gov/28466199/.

[8] Human Rights Campaign Found., Understanding Disability in the LGBTQ+ Community, Human Rights Campaign (Aug. 12, 2022), https://www.hrc.org/resources/understanding-disabled-lgbtq-people.

[9] See, e.g., Lauren J.A. Bouton et al., Williams Inst., LGBT Adults Aged 50 and Older in the US During the COVID-19 Pandemic (2023), https://williamsinstitute.law.ucla.edu/publications/older-lgbt-adults-us/; Bianca D.M. Wilson et al., Williams Inst., Racial Differences Among LGBT Adults in the U.S.: LGBT Well-Being at the Intersection of Race (2022), https://williamsinstitute.law.ucla.edu/wp-content/uploads/LGBT-Race-Comparison-Jan-2022.pdf.

[10] See, e.g., Jody L. Herman & Kathryn K. O'Neill, Williams Inst., Well-Being Among Transgender People During the COVID-19 Pandemic (2022), https://williamsinstitute.law.ucla.edu/wp-content/uploads/Trans-Pulse-Toplines-Nov-2022.pdf.

[11] See generally Ilan H. Meyer et al., Williams Inst., LGBTQ People in the US: Select Findings from the Generations and TransPop Studies (2021), https://williamsinstitute.law.ucla.edu/wp-content/uploads/Generations-TransPop-Toplines-Jun-2021.pdf (results of a nationally-representative sample of LGBTQ people).

[12] M. V. Lee Badgett et al., Williams Inst., LGBT Poverty In The United States: A Study Of Differences Between Sexual Orientation and Gender Identity Groups (2019), https://williamsinstitute.law.ucla.edu/wp-content/uploads/National-LGBT-Poverty-Oct-2019.pdf; see also Bianca D.M. Wilson et al., Williams Inst., LGBT Poverty in the United States (2023), https://williamsinstitute.law.ucla.edu/wp-content/uploads/LGBT-Poverty-COVID-Feb-2023.pdf (using data from the Behavioral Risk Factor Surveillance System and the Census Bureau’s Household Pulse Survey to analyze poverty rates during the early days of the COVID-19 pandemic). 

[13] See, e.g., Choi & Meyer, supra note 3, at 8 (finding that when compared to their cisgender counterparts, transgender older adults “may seek more frequent and intimate health care due to age related physical conditions and disabilities”).

[14] See Institute of Medicine, The Health Of Lesbian, Gay, Bisexual, And Transgender People: Building A Foundation For Better Understanding 20–21 (2011), https://www.ncbi.nlm.nih.gov/books/NBK64806; see also Logan S. Casey et al., Discrimination in the United States: Experiences of Lesbian, Gay, Bisexual, Transgender, and Queer Americans, 54 Health Servs. Research 1454 (2019), https://pubmed.ncbi.nlm.nih.gov/31659745/.

[15] Kate Cooper et al., The Phenomenology of Gender Dysphoria In Adults: A Systematic Review and Meta-Synthesis, 80 Clinical Psychology Rev. 101875 (2020), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7441311/.

[16] See, e.g., Lauren S.H. Chong et al., Experiences and Perspectives of Transgender Youths in Accessing Health Care: A Systematic Review, 175 JAMA Pediatrics 1159 (2021), https://jamanetwork.com/journals/jamapediatrics/article-abstract/2782148.

[17] See, e.g., You Don’t Want Second Best” Anti-LGBT Discrimination in US Health Care, Human Rights Watch (July 23, 2018), https://www.hrw.org/report/2018/07/23/you-dont-want-second-best/anti-lgbt-discrimination-us-health-care.

[18] Human Rights Campaign, LGBTQ+ Americans Under Attack: A Report and Reflection On The 2023 State Legislative Session (2023), https://hrc-prod-requests.s3-us-west-2.amazonaws.com/Anti-LGBTQ-Legislation-Impact-Report.pdf.

[19] Exec. Order. 14075, Advancing Equality for Lesbian, Gay, Bisexual, Transgender, Queer, and Intersex Individuals, 87 Fed. Reg. 37,189 (June 15, 2022).

[20] Nat’l Science & Technology Council, Federal Evidence Agenda on LGBTQI+ Equity (2023), https://www.whitehouse.gov/wp-content/uploads/2023/01/Federal-Evidence-Agenda-on-LGBTQI-Equity.pdf.

[21] Id. at 3.

[22] See generally Nat’l Academies Of Sciences, Engineering, & Med., Measuring Sex, Gender Identity, And Sexual Orientation (2022), https://nap.nationalacademies.org/catalog/26424/measuring-sex-gender-identity-and-sexualorientation.

[23] Id. at 52–55, 67.

[24] OMB, Recommendations on the Best Practices for the Collection of Sexual Orientation and Gender Identity Data on Federal Statistical Surveys 3 (2023), https://www.whitehouse.gov/wp-content/uploads/2023/01/SOGI-Best-Practices.pdf.

[25] Nat’l Academies Of Sciences, Engineering, & Med., supra note 22.

[26] Id. at 8.

[27] Id.

[28] OMB, supra note 24, at 4.

[29] HUMAN RIGHTS CAMPAIGN FOUND., HEALTHCARE EQUALITY INDEX 2022 (2022) https://reports.hrc.org/hei-2022

[30] Melanie Blackless et al., How Sexually Dimorphic Are We? Review And Synthesis, 12 Am. J. Human Biology 151 (2000).

[31] Nat’l Academies Of Sciences, Engineering, & Med, Understanding the Well-Being of LGBTQI+ Populations 26–28 (2020), https://doi.org/10.17226/25877.

General Comments on USCDI v5

Dear ONC Officials,

Please accept this letter from the National Association of Community Health Centers, which contains general content about opportunities to support USCDI updates and implementation in health centers.

Thank you for your work,

Julia Skapik, MD, MPH, FAMIA

CMIO, NACHC

2024-04-12 NACHC USCDIv5 Comments.docx

Orders and Laboratory Comments

Thank you for the opportunity to provide comments on Orders (focusing on laboratory orders) and Laboratory Data (focusing on UDIs) in the attached document.  I also support comments made by Regenstrief Institute and the Association for Pathology Laboratories (APHL) with further detail about many laboratory data elements.  APHL includes requirements of these elements in accord with other regulations and standards.  

Laboratory is a complex and challenging area, including electronically capturing, encoding, storing, exchanging and maintaining the data associated with the complete computerized meaning of tests across the healthcare ecosystem.  ONC and the HITAC Committees and Taskforces are applauded for their efforts to advance interoperability in this and other areas of healthcare.

 

 

USCDI v5 Public Comments APitkus 15Apr24.pdf

OCHIN Comments on Draft USCDI V5

Please see attached document for OCHIN's comments on the Draft USCDI v5. Thank you for your consideration.

DUHS Comments on USCDI v5

April 15, 2024
Micky Tripathi, Ph.D., M.P.P., National Coordinator for Health IT
Steven Posnack, M.S., M.H.S., Deputy National Coordinator for Health IT
Office of the National Coordinator for Health Information Technology
Office of the Secretary, United States Department of Health and Human Services


Re: Request for Public Comment, Draft United States Core Data for Interoperability (USCDI) v5
Submitted electronically to https://www.healthit.gov/isa/united-states-core-data-interoperability-uscdi#draft-uscdi-v5


Dear Dr. Tripathi and Mr. Posnack,


Duke University Health System submits the following comment regarding ONC’s Request for Public Comment on the Draft USCDI v5 posted in January, 2024. Duke University Health System is a world-class hospital and health care network supported by outstanding and renowned clinical faculty, nurses and care teams. Duke's services span the full continuum of care, from primary care to medical and surgical specialties and subspecialties, all dedicated to putting our patients at the forefront of everything we do. Our health system includes three hospitals – Duke University Hospital, Duke Regional Hospital and Duke Raleigh Hospital which serves a diverse population providing serving patients from all over the world.
We welcome the opportunity to review and comment on the proposed USCDI v5.


Knowing a patient’s sexual orientation, gender identity, sex assigned at birth, name used, and pronouns, as well as their anatomical inventory, is necessary in order to provide culturally affirming and responsive health care. Everyone deserves to be treated with respect regardless of gender identity and expression, and ensuring that systems and processes treat all genders equally which also means equitable healthcare.


Collecting SOGI data allows us measure disparities and is essential in providing the highest quality of care to our patients.
We are encouraged by the data elements that are included in USCDI v5 and especially like the addition of “name to use.”
Thank you for the opportunity to comment on USCDI v5. We appreciate your support of SOGI data collection, and collection of pronouns and “name to use,” to improve quality of care and to enhance LGBTQIA+ health equity. Should you have any questions, please contact Kirti P Loper, Program Manager, kirti.loper@duke.edu.


Sincerely,
Kirti P Loper
Program Manager, Employee Experience
Duke University Health System

APHL Comments on USCDI Draft V5

The Association of Public Health Laboratories (APHL) thanks you for the opportunity to provide feedback on draft version 5 of the US Core Data for Interoperability (USCDI). Please see attached document.

APHL USCDI V5 Comment Letter_0.pdf

Please see the attached…

Please see the attached comments from the American Academy of Pediatrics on the draft USCDI v5.

AAP Comments on USCDI Draft v5.pdf

Phreesia's Comments to USCDI V5

April 15, 2024

 

Micky Tripathi, Ph.D., M.P.P. 

Office of the National Coordinator for Health Information Technology (ONC) 

U.S. Department of Health and Human Services 

330 C Street SW, 7th Floor 

Washington, DC 20201

 

Re: USCDI Version 5

Dear Dr.Tripathi:

Thank you for the opportunity to provide comments and feedback on data elements for inclusion into United States Core Data for Interoperability (USCDI). Phreesia is the trusted leader in patient activation, giving providers, health plans, life sciences companies and other organizations tools to help patients take a more active role in their care. Founded in 2005, Phreesia enabled more than 150 million patient visits in 2023–more than 1 in 10 visits across the U.S.–scale that we believe allows us to make meaningful impact. Offering patient-driven digital solutions for intake, outreach, education and more, Phreesia enhances the patient experience, drives efficiency, and improves healthcare outcomes. As a routine course of business, we integrate with more than 80% of the U.S. electronic health record (EHR) market. 

Core to Phreesia is helping patients take a more active role in their care. As such, underpinning our comments is the desire to capture the patient’s voice as an input and source of truth, where appropriate, in their own medical record. Patients can and should be a contributor to their own EHR. 

Recommendation 1: Capture Patient Reported Data

Self-reported data is regarded as the gold standard because some data is most accurately captured from the patient directly, including demographics, social drivers of health, symptoms, and outcomes reporting. A recent study highlights the importance of capturing race and ethnicity data specifically from patients given the high rates of missing information, or worse yet, misclassification found in EHRs today.[1] The USCDI does not require that any data be captured from the patient, nor does it designate the patient, or their representative, as the preferred author for select data. We encourage ONC to require that select, relevant data be captured via the patient while designating other, relevant USCDI data as preferred patient authorship. In parallel, we urge that any patient reported data, whether patient authorship is preferred or mandated, be clearly distinguished from other clinical data. Doing so will appropriately amplify the patient’s voice, ensure patients can be partners in healthcare decisions, and active participants in their care.

Phreesia also supports HL7’s ongoing efforts to improve upon the capture of patient reported outcomes.  Phreesia remains steadfast in better linking questions and their responses in patient forms consistently, and in a manner that encourages healthcare organizations to include structures that capture trends over time. This is vital to the successful adoption of patient reported outcome performance measures. 

Recommendation 2: Promote Inclusivity, Health Equity, and Better Health Outcomes through Pronoun Capture

We support and applaud ONC’s recommendations to include pronouns in patient demographics and information data. Doing so promotes inclusivity, health equity, and improved health outcomes. We recommend that ONC require capture of pronoun data from patients and leverage a standardized, multiple-select, individual pronouns list to enable patients to select, representative pronouns. In the absence of nationally recognized coding systems, we ask ONC to carefully consider the cardinality of pronoun options to ensure representativeness. In addition to inclusive and multi-select selections lists, we recommend that ONC offer manual data entry options, leveraging affirmative statements such as “I identify as _____” or “My pronoun is _____”.   

We would be remiss not to highlight the importance of patient reported data via patient-facing apps, like Phreesia, for this very purpose. Capturing pronoun data directly from the patient via a patient facing-app overcomes apprehension and other sensitivities about asking patients for this information in a setting where the patient may feel a lack of privacy, or experience stigma.  Phreesia gives patients the ability to comfortably and securely self-identify in a consistent way while affording ease of integration into various systems of records. Given the value of these data for clinical care, we believe every effort should be made to make the process of self-identification safe and seamless for patients.

Recommendation 3: Enhance Medication Data Elements

Phreesia echoes the joint recommendations submitted by the Centers for Disease Control and Prevention (CDC) and the Centers for Medicare and Medicaid Services (CMS) to further differentiate between active, ordered, administered, and prescribed prescription drugs among the universal data elements. Without this distinction, medication management is extraordinarily difficult. We concur with CMS and the CDC that these changes to USCDI will enhance patient safety, quality improvement, and public health and lead to better patient care through appropriate education and engagement. Given Phreesia’s focus on patient reported data, we also recommend capturing patient reported information on adherence and side effects.

We thank ONC for the continued focus on data standardization and interoperability and appreciate the opportunity to comment. Phreesia is committed to collaborating with ONC and other stakeholders on USCDI.  We also look forward to continued evolution of the US Core Implementation Guide to not only ensure the USCDI V5 data elements can be effectively and appropriately utilized, but to ensure use cases keep pace with changes in the delivery of, expectations for, and innovations available in, healthcare.  Feel free to contact us for more information on these comments or to serve as a resource going forward.

 Sincerely,

Kristen Ballantine

Vice President, Public Affairs


 

[1] A systematic review. Am J Surg. 2023 Oct;226(4):463-470. doi: 10.1016/j.amjsurg.2023.05.011. Epub 2023 May 18. PMID: 37230870

USCDI+

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