Oregon Health Authority ISA Comments

Oregon is pursuing multiple approaches to address unmet needs related to SDOH. We support the inclusion of standards for representing housing insecurity, representing food insecurity, and representing transportation insecurity. Although PRAPARE is one commonly used screening tool, other validated tools also are in widespread use. We encourage the inclusion of coding for additional screening tools as available, building on the work of the Gravity Project.

OHA ISA Comments on letterhead__0.pdf

Comments from the Alliance for Nursing Informatics

Thank you for the opportunity to provide comments on the Interoperability Standards Advisory (ISA) and the Standards Version Advancement Process (SVAP).

ANI strongly endorses social determinants of health (SDOH) as a key interoperability need for better care and health nationwide, amplified as a need during the COVID-19 public health emergency. While SDOH data elements are present within the ISA, but adoption is low, and standards are not federally required. Therefore, ANI strongly supports further development to include SDOH standards in regulations and as federal program requirements.

Please see attachment for our full comments.


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 Transportation Insecurity. The CPT Evaluation and Maintenance services include assessing a patient’s level of transportation insecurity. Care plan services also address transportation needs.

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.