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:

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.