You can find the data here:
Here's my initial thoughts on each section:
Draft V1
I've already made the point that Provenance needs clarification. I should also like to point out that there really shouldn't be that much of a distinction between clinical notes and diagnostic imaging (or other narrative) text reports.
Proposed V2
Admission and Discharge Dates and Locations: FHIR and C-CDA? Really? Well sure if you want to put these into Encounter resources/classes (those have everything you need). But the most common use of ADT information in healthcare setting is notification. Payers want to know when their patients have been admitted, providers want to know when their patients have been hospitalized. ADT is current state of are and is being use today. Ideally, we'd shift to FHIR but we should probably focus on the fact that this is Notification, not push/pull data for the most part.
Cognitive and Functional Status: Been there, did that, not quite but almost a decade ago. This is honestly more a matter of coming up with the right value sets in LOINC and SNOMED than any structural problem, and those have already been determined and refined over the last half decade pretty decently.
Discharge Instructions: I seem to recall this is in 2015 CERHT standards today, why would that be delayed until 2019. This is such a common comment, let me note the other section it applies to below:
For 2019: Gender Identity, Pediatric Vitals, Pregnancy Status,
For 2020: Care Provider Demographics, Care Team Members Contact Information,
For 2021: Referring Provider
Emergent: Alive Status/Date of Death, Care Provider Licenses/Identifiers, Health Insurance Information
Some other general comments:
Family History: Wow, the definition is totally crazy on this one. Compare:
Information about all guardians and caregivers (biological parents, foster parents, adoptive parents, guardians, surrogates, and custodians), siblings, and case workers; with contact information for each.
To: "information about the genetic family members, to the extent that they are known, the diseases they suffered from, their ages at death, and other relevant genetic information." [HITSP C83, Section 2.2.1.25],
OR: "data defining the patient’s genetic relatives in terms of possible or relevant health risk factors that have a potential impact on the patient’s healthcare risk profile." [C-CDA Release 2.1],
OR: "significant health events and conditions for a particular individual related to the subject." [FHIR STU3]
You don't need the contact info, you want the "Health History". You aren't going to call these people because "HIPAA" (or at least as the provider understands it, not as written).
Diagnostic Imaging Reports: WHY are these (or other diagnostic reports) treated differently than clinical notes. Puhleeze.
Practitioner Responsible for Care: That's simply a role for a care team member. Pick a code, any single code to identify this, and the standards already handle it.
Communication Facilitators: This is clearly a category person A dreamed up (translators) and person B added to (hearing aids), and since both were about communication, fell into this bucket. Err, NO. One is part of the care team (albeit with a very specialized role), and the other is a piece of durable medical equipment. And if a provider wants to know what is needed to communicate with the patient, they should look in both places.
Reconciled Med List: Flag on an existing class, NOT a brand new class of information. This applies elsewhere as well.
Special Instructions: A truly insignificant variation on discharge instructions.
Cognitive and Functional Status: Been there, did that, not quite but almost a decade ago. This is honestly more a matter of coming up with the right value sets in LOINC and SNOMED than any structural problem, and those have already been determined and refined over the last half decade pretty decently.
Discharge Instructions: I seem to recall this is in 2015 CERHT standards today, why would that be delayed until 2019. This is such a common comment, let me note the other section it applies to below:
For 2019: Gender Identity, Pediatric Vitals, Pregnancy Status,
For 2020: Care Provider Demographics, Care Team Members Contact Information,
For 2021: Referring Provider
Emergent: Alive Status/Date of Death, Care Provider Licenses/Identifiers, Health Insurance Information
Some other general comments:
Family History: Wow, the definition is totally crazy on this one. Compare:
Information about all guardians and caregivers (biological parents, foster parents, adoptive parents, guardians, surrogates, and custodians), siblings, and case workers; with contact information for each.
To: "information about the genetic family members, to the extent that they are known, the diseases they suffered from, their ages at death, and other relevant genetic information." [HITSP C83, Section 2.2.1.25],
OR: "data defining the patient’s genetic relatives in terms of possible or relevant health risk factors that have a potential impact on the patient’s healthcare risk profile." [C-CDA Release 2.1],
OR: "significant health events and conditions for a particular individual related to the subject." [FHIR STU3]
You don't need the contact info, you want the "Health History". You aren't going to call these people because "HIPAA" (or at least as the provider understands it, not as written).
Diagnostic Imaging Reports: WHY are these (or other diagnostic reports) treated differently than clinical notes. Puhleeze.
Practitioner Responsible for Care: That's simply a role for a care team member. Pick a code, any single code to identify this, and the standards already handle it.
Emergent Stuff
There's a whole class of other, non-clinical documents. Deal with these mostly as you do for anything else not structured. That goes for Advanced Care Planning, Minor Consent, and possibly Emancipation Status.Communication Facilitators: This is clearly a category person A dreamed up (translators) and person B added to (hearing aids), and since both were about communication, fell into this bucket. Err, NO. One is part of the care team (albeit with a very specialized role), and the other is a piece of durable medical equipment. And if a provider wants to know what is needed to communicate with the patient, they should look in both places.
Reconciled Med List: Flag on an existing class, NOT a brand new class of information. This applies elsewhere as well.
Special Instructions: A truly insignificant variation on discharge instructions.
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