There are basically three different kinds of problems and one non-problem that we thought we might find:
- Things that just don't work without a fix to one specification or the other.
- Things that do work, but which are ugly if we are to use them, and so we'd like to make some changes to resolve them.
- Things that could work but might need some clarification or explanation as to how to resolve in the Asynchronous Bilateral Cutover case where a dual-capable C-CDA was being used.
- Things that simply work (which isn't really a problem).
There are also three different levels of compatibility that we likely needed to address:
- Cases where the incorporate provisions of the rule would be impacted. These are cases where the C-CDA entries are required to be transferred in some way to the EHR, such as with problems, medications, and medication allergies.
- Cases where the viewing requirements might be impacted (different section requirements), or where clinical content varied between versions of a document. For example, the Care Plan Section in C-CDA 1.1 includes Goals content, but in 2.0, there is a separate goals section.
- Cases where other ("secondary") uses of the content, such as with quality measures, would potentially be impacted. These are not specifically requirements of the Certification rule, but are capabilities that some have used to facilitate other requirements.
The essential feedback from the evaluation is that it is technically feasible to create a C-CDA document that supports both specifications and which might be understood by both systems. However, such a solution seems to be more technically challenging that any would like. HL7 members think we can do better.
The solution appears to be to quickly issue a DSTU Update of C-CDA to address these issues. Because of the timing of the regulation, we think this might be workable, but there are still a bunch of ducks we need to get in a row and then shot down.
SDWG will be seeking advice from its steering division and the TSC this evening, and will likely be taking action on it based on the outcomes. I will report more on this later in the week (perhaps as early as tomorrow). Those I have discussed this with seem to think that it is feasible.
We have maybe six weeks to accomplish this task. Due to the work of the Dual C-CDA task force we have an idea of what changes would need to be quickly implemented. Here is how I think the timing works:
The ONC comment period closes in a month. They will take at least two months to review the comments and produce a new rule, perhaps three. One month before they submit the final rule, they have to have the published content available. That gives us six weeks (not counting this one) to get 'er done.
Your action item is to reference an updated C-CDA in your comments on the Standards and Certification rule. The only way to ensure that ONC references a new edition is for a) HL7 to make one available quickly, and B) for you to make comments referencing the C-CDA DSTU Update.
To submit a comment, click the link above, and hit the SUBMIT A FORMAL COMMENT button on the right hand size underneath the the title.