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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:

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.