Ballot SubmissionTriage & Committee ResolutionBallot Comment Tracking
Comment NumberBallotChapterSectionPage #Line #Artifact IDResource(s)HTML Page name(s)URLVote and TypeSub-categoryTracker #Existing WordingProposed WordingBallot CommentSummaryIn person resolution requestedComment groupingScheduleTriage NotePubsDisposition WGDispositionDisposition Comment or Retract/Withdraw detailsDisposition/Retract/ Withdrawal DateMover / seconderFor AgainstAbstainRetracted / WithdrawnDisposition External OrganizationResponsible PersonChange AppliedSubstantive ChangeSubmitted ByOrganizationOn behalf ofCommenter EmailSubmitter Tracking IDReferred ToReceived FromNotes
1SDNEGSee comments from KP Sethi**website comment**Refers to other commenterLiora AlschulerLantana Consulting Groupliora.alschuler@lantanagroup.com
2SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterJoel Bales MA, MHAPEO DHMS - DoD/VA Interagency Program Officebales_joel@bah.com
3SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterMark BellezzaPEO DHMS - DoD/VA Interagency Program Officemark.a.bellezza.civ@mail.mil
4SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterKenneth BlountPEO DHMS - DoD/VA Interagency Program Officekenneth.d.blount.civ@mail.mil
5SDA-SA common error seen in dates is when certain "signal" dates representing an unknown or null value are retrieved using JDBC/ODBC an incorrectly interpreted as a date. Such special valued dates generally reflect that a date wasn't actually entered, but the code generating the CDA doesn't detect this condition. This is especially true in cases where Microsoft Access is the database storing the data.**website comment**Persuasive with modEPOCH dates SHALL not be present in date/time fields. There SHALL be no dashes in date/time fields. For some platforms, the EPOCH date is 1970-01-01 00:00 UTC, Microsoft Access uses 1899-12-30 00:00 UTC, and other systems use 1960-01-01 00:00 UTC. Additonal rules related to EPOCH times are out of scope at this time. Consider a larger project in concert with Sequoia to identify all date/time related issues. Gay/Ben1400Keith Boone MBIAudacious Inquirykboone@ainq.com
6SDNEGSee comments submitted by Andrew Statler**website comment**Refers to other commenterHans Buitendijk MScCerner Corporationhans.buitendijk@cerner.com
7SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterDave Carlson Ph.D.U.S. Department of Veterans Affairsdcarlson@xmlmodeling.com
8SDNEGSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Michael_Clifton_20190429100748.xls' that was uploaded to to the ballot website.**website comment**Refers to other commenterMichael CliftonEpicmclifton@epic.com
9SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterYvonne ColePEO DHMS - DoD/VA Interagency Program Officeyvonne.m.cole-clingerman.civ@mail.mil
10SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterKathleen ConnorU.S. Department of Veterans Affairskathleen_connor@comcast.net
11SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterMike DavisU.S. Department of Veterans Affairsmike.davis@va.gov
12SDNEGNeed to include discussion of provenance, at document, section and element level.**website comment**Block vote 2Future possible RubricsNot relatedOut of scope - this could possibly be a future Rubric as maturity of provenance progresses and is in practice.Gay/Calvin2200Gary Dickinson FHL7CentriHealthgary.dickinson@ehr-standards.com
13SDNEGSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_George_Dixon_20190403164752.xls' that was uploaded to to the ballot website.**website comment**Refers to other commenterGeorge DixonAllscriptsgeorge.dixon@allscripts.com
14SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterMinh-Huong DoanPEO DHMS - DoD/VA Interagency Program Officeminh-huong.l.doan.mil@mail.mil
15SDNEGSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_gaye_dolin_20190429191533.xls' that was uploaded to to the ballot website.**website comment**Refers to other commenterGay Dolin MSN RNIntelligent Medical Objects (IMO)gdolin@imo-online.com
16SDA-SSee comments by Scott Robertson**website comment**Refers to other commenterJames FergusonKaiser Permanentejamie.ferguson@kp.org
17SDNEGSee Comments from Andrew Statler**website comment**Refers to other commenterSteven FineCerner Corporationsfine@cerner.com
18SDNEG“see Kanwarpreet Sethi’s comments”**website comment**Refers to other commenterAngela FlanaganLantana Consulting Groupangela.flanagan@lantanagroup.com
19SDNEGSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Benjamin_Flessner1_20190425120925.xls' that was uploaded to to the ballot website.**website comment**Refers to other commenterBenjamin FlessnerRedoxbenjamin@redoxengine.com
20SDNEGsee Kanwarpreet Sethi’s comments**website comment**Refers to other commenterZabrina Gonzaga MSNLantana Consulting Groupzabrina.gonzaga@lantanagroup.com
21SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterKim Heermann-DoPEO DHMS - DoD/VA Interagency Program OfficeKimberly.heermann-do@va.gov
22SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterChris HillsPEO DHMS - DoD/VA Interagency Program Officechristopher.j.hills.civ@mail.mil
23SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterCatherine Hoang BSN, MSU.S. Department of Veterans AffairsCatherine.Hoang2@va.gov
24SDA-SSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_emma_jones_20190429221917.xls' that was uploaded to to the ballot website.**website comment**Refers to other commenterEmma JonesAllscriptsemma.jones@allscripts.com
25SDA-SSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Thomson_Kuhn_20190427172725.xls' that was uploaded to to the ballot website.**website comment**Refers to other commenterThomson KuhnAmerican College of Physicianstkuhn@acponline.org
26SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterMichael Lincoln MDU.S. Department of Veterans Affairsmlincoln1@gmail.com
27SDNEGSee Comments from Andrew Statler**website comment**Refers to other commenterLawrence McKnightCerner Corporationlawrence.mcknight@cerner.com
28SDA-SSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Linda_Michaelsen_20190429215552.docx' that was uploaded to to the ballot website.**website comment**Refers to other commenterLinda MichaelsenOptumlinda.michaelsen@optum.com
29SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterSean MuirU.S. Department of Veterans Affairssean.muir@jkmsoftware.com
30SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterGalen Mulrooney MBAU.S. Department of Veterans Affairsgalen.mulrooney@jpsys.com
31SDNEGSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Lisa_Nelson_20190429221900.xls' that was uploaded to to the ballot website.**website comment**Refers to other commenterLisa Nelson MS, MBAMaxMDLNelson@max.md
32SDA-SSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Craig_Newman_20190426132335.xls' that was uploaded to to the ballot website.**website comment**Refers to other commenterCraig NewmanAltarumcraig.newman@altarum.org
33SDA-SPlease comments from Scott Robertson**website comment**Refers to other commenterElizabeth NewtonKaiser Permanenteelizabeth.h.newton@kp.org
34SDA-SSee comments from Scott Robertson**website comment**Refers to other commenterCathy PlattnerKaiser PermanenteCathy.P.Plattner@kp.org
35SDNEGRefer to comments from Brett Marquard.**website comment**Refers to other commenterCarlos PolkPEO DHMS - DoD/VA Interagency Program Officecharles.b.polk6.civ@mail.mil
36SDNEGSee comments submitted by Andrew Statler**website comment**Refers to other commenterDouglas PrattCerner CorporationDoug.Pratt@cerner.com
37SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterCamala PricePEO DHMS - DoD/VA Interagency Program Officecamala.m.price.civ@mail.mil
38SDA-SEvery rubric should have an associated ID based on the rules voted on by the SDWG. Please add an ID for each rubric.**website comment**Block Vote 1PersuasiveImplement as ProposedMatt Rahn/Austin Kreisler2200Matt RahnOffice of the National Coordinator for Health ITMatthew.Rahn@hhs.gov
39SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterBelle RogersPEO DHMS - DoD/VA Interagency Program Officerogers_belle@bah.com
40SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterKen RubinU.S. Department of Veterans Affairsken.rubin@utah.edu
41SDNEGSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Kanwarpreet_Sethi_20190429153557.xls' that was uploaded to to the ballot website.See Kanwarpreet Sethi's comments**website comment**Refers to other commenterKanwarpreet SethiLantana Consulting Groupkp.sethi@lantanagroup.com
42SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterChris ShawnU.S. Department of Veterans Affairschristopher.shawn2@va.gov
43SDNEGRefer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterIoana Singureanu MSCs, FHL7U.S. Department of Veterans Affairsioana.singureanu@bookzurman.com
44SDNEGSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Andrew_Statler_20190429211054.xls' that was uploaded to to the ballot website.The rubric requirements need more support behind them to clarify what the expectation is and how they are actually going to measure them. It is unclear based on this document what many of the items mean and how they intend to actually measure the items.**website comment**Persuasive with modThe workgroup concurs that rubric needs to be testable. The test needs to be able to be executed on data that is available in the document. Align with Companion Guide before Rubric is published.Gay Dolin/Michael Clifton1200Andrew StatlerCerner CorporationAndrew.Statler@cerner.com
45SDNEGSee document 'HL7_C-CDA_RUBRIC_R1_I1_2019MAY_Greg_Staudenmaier_20190429185833.xls' that was uploaded to to the ballot website.Refer to the ballot comment spreadsheet submitted by Greg Staudenmaier.**website comment**Refers to other commenterGreg StaudenmaierU.S. Department of Veterans Affairsgreg.staudenmaier@va.gov
46SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterNorman Stone MDPEO DHMS - DoD/VA Interagency Program Officenorman.e.stone4.mil@mail.mil
47SDA-Ssee comments by7 Scott Robertson**website comment**Refers to other commenterSandra StuartKaiser Permanentesandra.stuart@kp.org
48SDA-SSee comments from Scott Robertson**website comment**Refers to other commenterWalter Suarez MD MPHKaiser Permanentewalter.g.suarez@kp.org
49SDNEGSee Comments from Andrew Statler**website comment**Refers to other commenterJenni SyedCerner Corporationjenni.syed@cerner.com
50SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterJoseph TerritoPEO DHMS - DoD/VA Interagency Program Officejoseph.territo@va.gov
51SDNEGRefer to comments from Brett Marquard**website comment**Refers to other commenterMellissa Walker BS, MAPEO DHMS - DoD/VA Interagency Program Officemellissa.a.walker.mil@mail.mil
52SD22.25A-TPatient DemographicsPatient Demographics US Realm HeaderThe Rubric identifies a column heading of "Section/Entry/Header" and then lists "Patient Demographics". That does not line up with any of the components in the header as there is no Section or Entry labeled "Patient Demographics" and the Header is "US Realm". There is not even a component in the header labeled "Patient Demographics". If the expectation is that generated C-CDA documents need to be more precise when there are many different variables that go into the creation including the build, then we need to make sure we are very clear about what we are evaluating and what standards are we using. There are many places in this document where it is unclear what is being evaluated, what standard is being applied, and what are the thresholds for success.matthReady to ImplementDocument FormatPersuasive with modUpdate to US Realm Header (Patient Demographics)Calvin Beebe/Matt Rahn601Andrew StatlerCerner Corporation
53SD22.25NEGPatient Date of Birth should be valid and properly precisionedIn the US Realm Header, the Ppatient Date of Birth birthTime should be valid and properly precisioned. As a valid date, presumably that means the date is recognized as a date on the Gregorian Calendar within the span of a reasonable human lifespan and not in the future. Per Conformance Statement 1198-5298, the precision SHALL be precise to the year, SHOULD be precise to the day, and in the case of a newborn, may need to be precise to the minute. Additional precision would be unexpected and unnecessary.While we agree with the fact of proper provisioning, it is not always easy to enforce precision, albeit we use it in limited instances. The autonomy to mandate based on precision values seems a bit prescriptive. Therefore we recommend this to be a warning at most.These entries deserve to have additional definition around them. This is specific to the patient birthTime. Persuasive with modMake a warning and put in Information section. Do not throw an error.2019-09-17Matt Rahn/Michael Clifton1200Andrew StatlerCerner Corporation
54SD22.25NEGPatient's alternative names such as birth name, previous name should exist in its own name element independent of the legal name.What is meant by "own name element" in this requirement? The Description basically says the same thing on this. I presume they mean that each name should get a new repetition of the US Realm Patient Name Template. I could interpret that incorrectly though to mean that we are being asked to put each name in a separate element, so when I look at US Realm Patient Name Template, I see that given name and prefix are 1 to many and 0 to many respectively. That means I could interpret that birth name and alternative name could just be given names. This needs some clarification.Ready to ImplementPersuasive with modUpdate to: Patient's alternative names such as birth name and previous name shall occur in separate name element instances. ALSO ADD EXAMPLE2019-09-17Calvin Beebe/Matt Rahn601Andrew StatlerCerner Corporation
55SD22.25NEGEncounters - EffectiveDate/Time elements should have the right time and time zone offsetsWe need to clarify that the date/time elements are not at the Section level, but in the entries that are part of the Encounters Section. If you have an "Encounters Section, Entries Optional", you wouldn't necessarily even have date/time elements at all. This is a rather vague requirement.Discuss on a callPersuasive with modWhen effectiveTime/time is present it should have the right time and time zone offsets - universally across rubric update EffectiveDate to EffectiveTime2019-09-18Matt Rahn/Calvin Beebe901Andrew StatlerCerner Corporation
56SD22.26NEGEncounters - EffectiveDate/Times for all historical activities should be within the lifespan on the patientAre we sure this clinically valid in the first place? In our EHR, these fields come from the clinical workflow. If they do not set a certain field for some reason, is it up to the interoperability solution to second-guess the intention of that user/solution and override what is likely in the clinical documentation within the EHR?It is discomforting to think that we have Interop solutions creating documents that are checking patient birth/death times and enforcing all activities like meds, tests, or other examinations that happen before birth or after death might be invalid because they fall outside the offical window of birthTime and deathTime.LifespanDiscuss on a callPersuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Calvin2400Andrew StatlerCerner Corporation
57SD22.27NEGEncounters - The Display Names used by the structured data should conceptually align with the meaning of the codeWe already use the nomenclature to populate the fields that exchange is driven from. It becomes a bigger challenge to ensure that all the display values are in alignment because those can often drive the values that clients see in their applications and sometimes clients will change those values to reflect something that is easier to read or comprehend in their particular setting. When they do this, it will throw off the ability to keep standard Nomenclature code system values and their related display/description values in alignment as they are sent in the C-CDA document. It should not be a requirement that those values always match. The purpose of having a coding system is so that you can match on the code value. If you force the systems to align on these secondary and tertiary fields and then maintain alignment on those, you are potentially distracting developers and providers from providing care or developing new solutions and instead forcing them to spend all their time maintaining existing solutions. We do not support the idea of forcing the display values to match in addition to the actual coded nomenclature values. If the coded value matches and the display value does not, you can offer a warning, but it should not be considered an error.DisplayName and Code allignmentThere are 6 duplicates to this comment that are therefore resolved (see "DisplayName and code alignmentTriage Note in "Comment Grouping Column")Not persuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error 2019-09-18Matt Rahn/Michael Clifton1400Andrew StatlerCerner Corporation
58SD22.27NEGEncounters - Each entry has to be linked to related narrative textThis is another example of the need to align the respective agencies and agree on a standard. Need clarity. This does not appear to be something specified in the 2.1 IG (only the 2.0) - if that's the case, this does not seem to be something legitimate for validation when the 2.1 IG is the standard. Until then this should be a warning. See this link for further discussion. http://wiki.hl7.org/index.php?title=Relationship_between_a_section_and_its_entries entry/textReferenceBlock Vote 2Propose dispo to commenterNot persuasiveIn R2.1 this is stated in volume 1 page 24 and 25 - as SHOULD conformances appliable to all entries.10/23/2019: "The C-CDA R1.1 release recommended that clinical statements include a link between the narrative (section.text) and coded clinical data (entry). Rather than repeat these constraints in every applicable entry, SDWG agreed in R2.0 to apply the following constraint to all entry templates, unless explicitly prohibited." In 2.1 we reasserted this in the template conformance statements. In addition, in encounter Activity text reference is a SHOULD The rubric often takes "SHOULD" requirments and make them a required rubric to encourage improved practice.Gay/Calvin2200Andrew StatlerCerner Corporation
59SD22.27NEGAllergies - EffectiveDate/Times for all historical activities should be within the lifespan on the patient EffectiveDate/low for historical events should be greater than one year prior to the patient's date of birth and effectiveTime/high less than the earliest of current time or patient's date of deathThis is extremely confusing, but in reality, this is the same issue as the historical activities on the encounters from page 6. The Description sounds like the low value for an allergy date should be at least a year before my birth if not more. Maybe we should call that allergy at 10 years before I was born to be safe. For the high, it needs to be any time less than right now since I'm still alive. Again, I think we are trying too hard to force dates in at the point of document creation when they may not actually exist in the patient chart.If the dates do not exist in the patient chart, I do not believe we should be putting them in for these allergies.LifespanDiscuss on a callNot persuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Calvin2400Andrew StatlerCerner Corporation
60SD22.27NEGThe Display Names used by the structured data should conceptually align with the meaning of the codeWe already use the nomenclature to populate the fields that exchange is driven from. It becomes a bigger challenge to ensure that all the display values are in alignment because those can often drive the values that clients see in their applications and sometimes clients will change those values to reflect something that is easier to read or comprehend in their particular setting. When they do this, it will throw off the ability to keep standard Nomenclature code system values and their related display/description values in alignment as they are sent in the C-CDA document. It should not be a requirement that those values always match. The purpose of having a coding system is so that you can match on the code value. If you force the systems to align on these secondary and tertiary fields and then maintain alignment on those, you are potentially distracting developers and providers from providing care or developing new solutions and instead forcing them to spend all their time maintaining existing solutions. DisplayName and Code allignmentdispo'd at WG with resolution to comment 57Not persuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error 2019-09-18Matt Rahn/Michael Clifton1400Andrew StatlerCerner Corporation
61SD22.28NEGAllergies - Allergen representation is correct The narrative name of the Allergen should represent the conceptual meaning of the code in the entryNeed clarification around the representation and conceptual meaning of an Allergen. We would also ask for any schema xPath representation as an example. Until then this should be a warning. entry/textReferenceBlock Vote 2Persuasive with modRubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Calvin2200Andrew StatlerCerner Corporation
62SD22.29NEGProblems - EffectiveDate/Times for all historical activities should be within the lifespan on the patientThis is extremely confusing, but in reality, this is the same issue as the historical activities on the encounters from page 6. The High and Low values for historical events should be sent as they appear in the patient's clinical record and should not be forced in the C-CDA creation.LifespanDiscuss on a callPersuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Calvin2400Andrew StatlerCerner Corporation
63SD22.29NEGProblems - The Display Names used by the structured data should conceptually align with the meaning of the code. We already use the nomenclature to populate the fields that exchange is driven from. It becomes a bigger challenge to ensure that all the display values are in alignment because those can often drive the values that clients see in their applications and sometimes clients will change those values to reflect something that is easier to read or comprehend in their particular setting. When they do this, it will throw off the ability to keep standard Nomenclature code system values and their related display/description values in alignment as they are sent in the C-CDA document. It should not be a requirement that those values always match. The purpose of having a coding system is so that you can match on the code value. If you force the systems to align on these secondary and tertiary fields and then maintain alignment on those, you are potentially distracting developers and providers from providing care or developing new solutions and instead forcing them to spend all their time maintaining existing solutions. DisplayName and Code allignmentdispo'd at WG with resolution to comment 57Not persuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error 2019-09-18Matt Rahn/Michael Clifton1400Andrew StatlerCerner Corporation
64SD22.210NEGProblems - The Problem narrative representation should be correct Problems - The Problem narrative representation should be a correct and accurate description of the coded problem entry. If the problem entry does not map to an item in the narrative, then it should be identified as "incorrect" and can be identified as an error.Need clarification around the representation of what is correct, and how it can be validated? Until then we suggest a warning entry/textReferenceBlock Vote 2Propose dispo to commenterNot persuasive with modWill modify text to: “Where a link between the narrative (section.text) and coded clinical data (entry) exists, the section.text must conceptually align with the meaning of the code it links with.” (aka, the code system display name). Will add one or more examples of "conceptually aligned" and "not conceptually alignedGay/Calvin2200Andrew StatlerCerner Corporation
65SD22.210NEGProblems - Narrative name of the problem should relate to the meaning of the code in the valueNeed clarification around the representation of how it relates, and how it can be validated? We would also ask for any schema xPath representation as an example. Until then we suggest a warning This requirement is unclear. What is it asking? How will it be measured?entry/textReferenceBlock Vote 2Propose dispo to commenterNot persuasive with modWill modify text to: “Where a link between the narrative (section.text) and coded clinical data (entry) exists, the section.text must conceptually align with the meaning of the code it links with.” (aka, the code system display name). Will add one or more examples of "conceptually aligned" and "not conceptually alignedGay/Calvin2200Andrew StatlerCerner Corporation
66SD22.210NEGMedications - Medications effective/time should minimally be represented to the day, but should reflect more specific time when such time is available (e.g., reflecting hospital MAR time specificity) So, while we agree with the fact of minimal representation to the day, it is not always easy to enforce precision, albeit we use it in limited instances. The autonomy to mandate based on precision values seems a bit prescriptive. Therefore we recommend this to be a warning. This requirement states that we should be more specific when such time is available. How do we identify when we should be more precise and we would shouldn't? Is this something the Scorecard will make a determination on? What is it using?Discuss with SDWGPersuasiveRemove rubric or align time with effective time description and proper formatting of effectiveTimeGay/Calvin2400Andrew StatlerCerner Corporation
67SD22.211NEGMedications - EffectiveDate/Times for all historical activities should be within the lifespan on the patient. EffectiveDate/low for historical events should be greater than one year prior to the patient's date of birth and effectiveTime/high less than the earliest of current time or patient's date of death. This is extremely confusing, but in reality, this is the same issue as the historical activities on the encounters from page 6. The High and Low values for historical events should be sent as they appear in the patient's clinical record and should not be forced in the C-CDA creation.I maintain that the C-CDA creation process should not put dates in for high and low if they are not in the patient chart. Doing so can have unintended consequences.LifespanDiscuss on a callPersuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Calvin2400Andrew StatlerCerner Corporation
68SD22.211NEGMedications - The Display Names used by the structured data should conceptually align with the meaning of the codeWe already use the nomenclature to populate the fields that exchange is driven from. It becomes a bigger challenge to ensure that all the display values are in alignment because those can often drive the values that clients see in their applications and sometimes clients will change those values to reflect something that is easier to read or comprehend in their particular setting. When they do this, it will throw off the ability to keep standard Nomenclature code system values and their related display/description values in alignment as they are sent in the C-CDA document. It should not be a requirement that those values always match. The purpose of having a coding system is so that you can match on the code value. If you force the systems to align on these secondary and tertiary fields and then maintain alignment on those, you are potentially distracting developers and providers from providing care or developing new solutions and instead forcing them to spend all their time maintaining existing solutions. There is also a burden to keep up with twice a year updates from VSAC. Our EHR is not using a centrally deployed list of coded values so each client would need to update this list.DisplayName and Code allignmentdispo'd at WG with resolution to comment 57Not persuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error 2019-09-18Matt Rahn/Michael Clifton1400Andrew StatlerCerner Corporation
69SD22.211NEGMedications - Substance administration effectiveTime should match the narrative This is too granular and prescriptive to mandate, we request clarification around the representation. There is a level of concern when systems are mandated to represent content within a free text element as clients are allowed to modify. We would also ask for any schema xPath representation as an example. Until then this should be a removedFreetext Sig can be difficult to parse and accurately identify the parts of the order. For this reason, we capture the discrete components of the order separately and those are signed by the provider, so it is possible that another system parsing the freetext sig could come to a different conclusion on the freetext sig.Free text sigBlock Vote 3Not persuasive with modActual Rubric: The Substance administration/effectiveTime @xsi:type = pivl should agree with the Free Text Sig information. ---------------- Dispostion: While we agree that this would be difficult and even inappropriate, for vendors to enforce restrictions on free text sig, 1) conflict checking could be developed and implemented 2) Even if conflict checking would be too difficult to implement for a vendor, the intent of this rubric is to encourage proper clinical documentation by the end user. “Poor” scorecard grades related to this can be attributed to the clinical user as opposed to the vendor. We will add clarifying text with this caveat and suggest tools provide the same caveat.Gay/Matt1900Andrew StatlerCerner Corporation
70SD22.212NEGMedications - Name of the drug should agree with the coded entryPlease provide more context/description.We could interpret this a number of ways, but would prefer to make sure we all have the same interpretation of this to start with.entry/textReferenceBlock Vote 2Propose dispo to commenterNot persuasive with modWill modify text to: “Where a link between the narrative (section.text) and coded clinical data (entry) exists, the section.text must conceptually align with the meaning of the code it links with.” (aka, the code system display name). Will add one or more examples of "conceptually aligned" and "not conceptually alignedGay/Calvin2200Andrew StatlerCerner Corporation
71SD22.212NEGMedications - The substance administration status code should not conflict with the medication status observationPlease provide more context/description.What does this refer to exactly?Not persuasive with modProposal: we remove this rubric all together, based on lack of implementer input and that (Medication Status Observation) template is not present in C-CDA R2.1 or since HITSP C32 Side Note: Consider a project to examine act Status vs clinical status in medications.Gay/Lisa1800Andrew StatlerCerner Corporation
72SD22.212NEGMedications - The substance administration/route code should reconcile with the medication consumablePlease provide more context/description.How will this be reconciled? Is there a list of drugs that will be aligned with a specific FormattingPersuasive with mod CHANGE TO WARNING ONLY WITH THE FOLLOWING CLARIFIED RULE: If the manufacturedMaterial.code RxNorm code is term type that includes dose form (SCDF, SCDG, SCD, GPCK, SBDF, SBDG, SBD, BPCK) than the sustanceAdministration.route.code and manufacturedMaterial.code should not conflictGay/Calvin1900Andrew StatlerCerner Corporation
73SD22.212NEGMedications - Medication status end time should be later than the document creation dateAgain somewhat prescriptive given there would have to be some type of data issue that would cause this to occur? We would recommend this as a warningThis is not necessarily true. If the provider just discontinued the patient's medication, it would have an end date of today or very recent. They may choose to leave the status as Active and they could have a very good clinical reason for doing so if the patient was on a drug that stays active in the system for a long time after the patient stops taking it. If they were on something that will be active in their system for 2 months and it could have contraindications with other meds or procedures, they would want to know that. Checking for a specific date/status combination and forcing one or the other when creating the document could lead to problems.Block Vote 3Not persuasiveActual Rubric: When Medication status is active the high time should be in the future relative to the document generation date or the effectiveTime/high could be not present 1) The examples stated are not clinically relevent. Half life of medications or genomic errors in metabolism are not equivilent to the medication end date 2) It would be highly unlikely that the medication that was d/c would stay active at the exact moment of document generation.Gay/Matt1900Andrew StatlerCerner Corporation
74SD 22.212NEGMedications - Machine readable should align with the narrativeWould be interested in seeing how this could be verified and mandated. Generally speaking services provide a level of flexibility to our client base causing this to be out of our clinical control. We recommend removalIn our EHR, the freetext sig is handled differently from the actual prescription components which are captured discretely and then verfied by the provider. There is no guarantee that the Freetext Sig would match.Free text sigBlock Vote 2Not persuasive with modWhile we agree that this would be difficult and even inappropriate, for vendors to enforce restrictions on free text sig, 1) conflict checking could be developed and implemented 2) Even if conflict checking would be too difficult to implement for a vendor, the intent of this rubric is to encourage proper clinical documentation by the end user. “Poor” scorecard grades related to this can be attributed to the clinical user as opposed to the vendor. We will add clarifying text with this caveat and suggest tools provide the same caveat.Gay/Calvin2200Andrew StatlerCerner Corporation
75SD22.212NEGMedications - The narrative should align with the meaning of the coded entryWould be interested in seeing how this could be verified and mandated. Generally speaking our services provide a level of flexibility to our client base causing this to be out of our clinical control. We send out RxNorm but the narrative is derived from the Rx Multum the end user selects. We recommend removalOur EHR uses a translation from an internal nomenclature to a standard nomenclature. What usually goes in the narrative is the information that the provider worked from while in the system, so it will be different than the translations that occur when the document is created, making it nearly impossible for these to align cleanly.entry/TextReferenceBlock Vote 2Not persuasive with modWill modify text to: “Where a link between the narrative (section.text) and coded clinical data (entry) exists, the section.text must conceptually align with the meaning of the code it links with.” (aka, the code system display name). Will add one or more examples of "conceptually aligned" and "not conceptually alignedGay/Calvin2200Andrew StatlerCerner Corporation
76SD22.213NEGImmunizations - EffectiveDate/Times for all historical activities should be within the lifespan on the patient.This is extremely confusing, but in reality, this is the same issue as the historical activities on the encounters from page 6. The High and Low values for historical events should be sent as they appear in the patient's clinical record and should not be forced in the C-CDA creation.LifespanDiscuss on callPersuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Calvin2400Andrew StatlerCerner Corporation
77SD22.213NEGImmunizations - The Display Names used by the structured data should conceptually align with the meaning of the code. EffectiveDate/low for historical events should be greater than one year prior to the patient's date of birth and effectiveTime/high less than the earliest of current time or patient's date of death.We already use the nomenclature to populate the fields that exchange is driven from. It becomes a bigger challenge to ensure that all the display values are in alignment because those can often drive the values that clients see in their applications and sometimes clients will change those values to reflect something that is easier to read or comprehend in their particular setting. When they do this, it will throw off the ability to keep standard Nomenclature code system values and their related display/description values in alignment as they are sent in the C-CDA document. It should not be a requirement that those values always match. The purpose of having a coding system is so that you can match on the code value. If you force the systems to align on these secondary and tertiary fields and then maintain alignment on those, you are potentially distracting developers and providers from providing care or developing new solutions and instead forcing them to spend all their time maintaining existing solutions. DisplayName and Code allignmentdispo'd at WG with resolution to comment 57Not persuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error 2019-09-18Matt Rahn/Michael Clifton1400Andrew StatlerCerner Corporation
78SD22.214NEGSocial History - EffectiveDate/Times for all historical activities should be within the lifespan on the patient. EffectiveDate/low for historical events should be greater than one year prior to the patient's date of birth and effectiveTime/high less than the earliest of current time or patient's date of death.This is extremely confusing, but in reality, this is the same issue as the historical activities on the encounters from page 6. The High and Low values for historical events should be sent as they appear in the patient's clinical record and should not be forced in the C-CDA creation.LifespanDiscuss on callPersuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Calvin2400Andrew StatlerCerner Corporation
79SD22.214NEGSocial History - The Display Names used by the structured data should conceptually align with the meaning of the code. We already use the nomenclature to populate the fields that exchange is driven from. It becomes a bigger challenge to ensure that all the display values are in alignment because those can often drive the values that clients see in their applications and sometimes clients will change those values to reflect something that is easier to read or comprehend in their particular setting. When they do this, it will throw off the ability to keep standard Nomenclature code system values and their related display/description values in alignment as they are sent in the C-CDA document. It should not be a requirement that those values always match. The purpose of having a coding system is so that you can match on the code value. If you force the systems to align on these secondary and tertiary fields and then maintain alignment on those, you are potentially distracting developers and providers from providing care or developing new solutions and instead forcing them to spend all their time maintaining existing solutions. DisplayName and Code allignmentdispo'd at WG with resolution to comment 57Not persuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error 2019-09-18Matt Rahn/Michael Clifton1400Andrew StatlerCerner Corporation
80SD22.213NEGLab Results - The effectiveTime is an interval that spans the effectiveTimes of the contained result observations.Help us understand the clinical significance of this rubric. Organizer/effectiveTimeBlock Vote 2Propose dispo to commenterNot persuasiveThe actual rubric is: "The effectiveTime interval in the Result Organizer must encompass the effectiveTimes of the observations within the organizer." From C-CDA: "(The results organizer) provides a mechanism for grouping result observations. It contains information applicable to all of the contained result observations." Therefor its stands to reason that the contained items would logically have either the same time, or if the organizer has a range, within that range. A classic example (and original intent of the Results Organizer), is to group together items that in the real clinical world ARE grouped together, for example(s), a CBC, and a chemistry panel. It would be clinically inappropriate to have a CBC (Panel) drawn (or resulted) 2019/10/28 @ 0600, to contain and RBC or WBC for 2019/10/27 @ 0600Gay/Calvin2200Andrew StatlerCerner Corporation
81SD22.217NEGVital Signs - BMI should match height and weightThis seems overly directed to an unspecified methodology used in adults and pediatrics to value the BMI. Suggest removal.BMIBlock Vote 2Propose dispo to commenterNot persuasive with modBody Mass Index is a simple calculation using a person’s height and weight. The formula is BMI = kg/m2 where kg is a person’s weight in kilograms and m2 is their height in meters squared. EHRs calculate BMI. Therefore, a BMI that is sent in a C-CDA should send the correct calculated value. We will clarify the rubric: If height and weight are present, the BMI value shall equal the patient’s weight in kilograms divided by the patient’s height in meters squared.Gay/Calvin2200Andrew StatlerCerner Corporation
82SD22.217NEGVital Signs - EffectiveDate/Times for all historical activities should be within the lifespan on the patient EffectiveDate/low for historical events should be greater than one year prior to the patient's date of birth and effectiveTime/high less than the earliest of current time or patient's date of death.This is extremely confusing, but in reality, this is the same issue as the historical activities on the encounters from page 6. The High and Low values for historical events should be sent as they appear in the patient's clinical record and should not be forced in the C-CDA creation.LifespanPersuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Calvin2400Andrew StatlerCerner Corporation
83SD22.217NEGVital signs and results should use a LOINC CodeWe already use the nomenclature to populate the fields that exchange is driven from. It becomes a bigger challenge to ensure that all the display values are in alignment because those can often drive the values that clients see in their applications and sometimes clients will change those values to reflect something that is easier to read or comprehend in their particular setting. When they do this, it will throw off the ability to keep standard Nomenclature code system values and their related display/description values in alignment as they are sent in the C-CDA document. It should not be a requirement that those values always match. The purpose of having a coding system is so that you can match on the code value. If you force the systems to align on these secondary and tertiary fields and then maintain alignment on those, you are potentially distracting developers and providers from providing care or developing new solutions and instead forcing them to spend all their time maintaining existing solutions. LOINC VS and ResultsBlock Vote 2Propose dispo to commenterNot persuasive with modThe actual rubric is: A LOINC Code must be used when coding vital signs and results. 1) There are duplicate rows under the "Vital signs" category - we will remove one 2) The base standard has a SHOULD binding to LOINC in Results already (CONF:1198-7133) 3) A later "Informational" states lab results SHOULD be from LOINC and SHOULD be from the top 2000 LOINC Lab codes 4) Therefore, this rubric is either conflicting or misplaced (meant to be just Vital Signs?) 5) WRT Vital Signs, Vital Sign Result Type is a SHOULD binding to LOINC value set 6) Assuming this rubric is intended for Vital signs, and the rubric intends to enforce the using of, minimally this Vital Sign Result Type Value set, and if not from this value set than from LOINC --------------------------------------------- 1) We will edit rubric to clarify this is for the Vital sign category and the rubric intends to enforce the using of, minimally this Vital Sign Result Type Value set, and if NOT from this value set than code must be from LOINC 2) We will clarify that the lab result rubric "SHOULD" is specified for the LOINC being from the top 2000 labs (b/c base standard already binds SHOULD to LOINC). WILL ADD OR if rad from https://loinc.org/download/loincrsna-radiology-playbook-file/ WILL NEED TO VALIDATE WITH LOINCGay/Calvin2200Andrew StatlerCerner Corporation
84SD22.321NEGLaboratory Tests and Results - The Display Names used by the structured data should conceptually align with the meaning of the code.We already use the nomenclature to populate the fields that exchange is driven from. It becomes a bigger challenge to ensure that all the display values are in alignment because those can often drive the values that clients see in their applications and sometimes clients will change those values to reflect something that is easier to read or comprehend in their particular setting. When they do this, it will throw off the ability to keep standard Nomenclature code system values and their related display/description values in alignment as they are sent in the C-CDA document. It should not be a requirement that those values always match. The purpose of having a coding system is so that you can match on the code value. If you force the systems to align on these secondary and tertiary fields and then maintain alignment on those, you are potentially distracting developers and providers from providing care or developing new solutions and instead forcing them to spend all their time maintaining existing solutions. This poses additional challenges since many clients use codes outside the 2000 standard LOINC values to reprsent the same things, so converging on a standard set of values will require clients to implement changes.DisplayName and Code allignmentdispo'd at WG with resolution to comment 57Not persuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error 2019-09-18Matt Rahn/Michael Clifton1400Andrew StatlerCerner Corporation
85SD6NEGEffectiveDate/Times for historical events should be greater than the patient's date of birth and less than the earliest of current time or patient's date of death.What defines "historical" ? An encounter document for a current admission may have a planned discharge date in the future. Or systems may choose to include upcoming appointments in this section. Precluding ANY future dates seems limiting. Similar in other sections.Ready to ImplementPersuasive with modEffectiveDate/Times for historical events should be no earlier than one year prior to patient's date of birth and no later than one year after the patient's date of death.2019-05-09Matt Rahn/Michael Clifton900Benjamin FlessnerRedox
86SD8A-QEffectiveDate/Time elements have the right time and time zone offsets - This should be removed.Should this have been removed?Persuasive with modWill remove the effective time for problemMatt Rahn/Benjamin Flessner900Benjamin FlessnerRedox
87SD5A-Stime offsets along with the date and are typically nonzero time offsets."Time offsets" are called "time components" in other CDA conformance statements (like Birth Date). Seeing them referred to as "offset" confuses them with the timezone (which IS an offset). Suggest calling them "time component" rather than "time offset."PersuasiveWill change the wording from Time Offset to Time ComponentMatt Rahn/Benjamin Flessner900Benjamin FlessnerRedox
88SD11A-TThe Substance administration/effectiveTime @institution specified should…The Substance administration/effectiveTime @institutionSpecified should…attribute name = one wordReady to ImplementPersuasiveWill remove the space and update the camelcase.Matt Rahn/Benjamin Flessner900Benjamin FlessnerRedox
89SD16A-TIf observation value is recorded as a PQ datatype and if present, the observation range should be coded as an “IVL_PQ”If observation value is recorded as a PQ datatype and a referenceRange is present, the referenceRange/observationRange should be coded as an “IVL_PQ”This is confusing. I assume this is talking about the referenceRange element Same comment on page 20Ready to ImplementPersuasiveUpdate text as proposedMatt Rahn/Benjamin Flessner900Benjamin FlessnerRedox
90SD20NEGAll Template Ids should be Valid for C-CDA and Supplemental IGs. If there is a valid template ID, but doesn’t align with above then provide an Informational message saying it’s an unrecognized template ID."provide an informational message" is inconsistent with the "throw an error" behavior of these required sections. Additional template IDs are always allowed, but there are some specific use cases you're looking for (e.g. C-CDA templateIds with non-date version attributes), they should be called out explicitly.Template IDsBlock Vote 2Propose dispo to commenter: Persuasive with mod1.C-CDA R2.1 template IDs in CDA R2.1 files should be the expected IDs as defined in C-CDA R2.1 and C-CDA Supplemental Templates 2.C-CDA R2.1 template IDs in CDA R2.1files should contain the version extension as defined in the C-CDA R2.1 IG 3.Additional template IDs are allowed in open templatesGay/Calvin2200Benjamin FlessnerRedox
91SDRequired RubricDemographics5A-SPatient Date of Birth should be valid and properly precisionedPatient Date of Birth must be valid and properly precisionedI struggle with the word "should" in a Required Rubric section. I suspect there is a distinction between "should" and "SHOULD" but it feels like there is a bit of a mixed message when "should" is used in this section (and it's quite common). It may be clearer to readers if stricter language is used in all Required Rubrics in all of the Rubrics and Descriptions in this section.Conformance verbsBlock Vote 2Persuasive with modWe will use SHALL with required Rubrics and SHOULD with informational rubrics. Violation of the SHALL rubrics will result in decreased scoring in any rubric tooling.Gay/Calvin2200Craig NewmanAltarum
92SDRequired RubricEncounters6A-SCheck if the Encounter date/time and ID in the header is present in one of the EncounterActivity entries in the Encounter section of the body. Check whether the encompassing encounter is present in all encounter based documents i.e. Discharge Summary, Referral Note, etc. (do not ding if using CCD/Care Plan)The Encounter date/time and ID in the header shall be present in one of the EncounterActivity entries in the Encounter section of the body. The encompassing encounter shall be present in all encounter based documents i.e. Discharge Summary, Referral Note, etc. (do not ding if using CCD/Care Plan)The wording for a couple of encounter related concepts is different in that it starts with "check" and reads more like instructions to the tool developers than a statement of a requirement. I suggest using the same format as other requirementsYesencompassingEncounterBlock Vote 2Propose dispo to commenter Note: Consult Note: SHALL encompassingEncounter Discharge Summary: SHALL encompassingEncounter Progress Note: SHALL encompassingEncounter Referral Note: encompassingEncounter is not required Transfer Summary: encompassingEncounter is not required Care Plan: SHOULD encompassingEncounter Persuasive with mod 1. Where encompassingEncounter is present in the C-CDA R2.1 header AND Encounter Activitie(s) are present in the body of the document, then the encompassingEncounter date/time and ID SHALL equal one of the encounter/IDs in one encounter activity in the body of the document 3) Remove this rubric: The encompassing encounter shall be present in all encounter based documents i.e. Discharge Summary, Referral Note, etc. (do not ding if using CCD/Care Plan)Gay/Calvin2200Craig NewmanAltarum
93SDRequired RubricAllergies8A-SEach entry has to be linked to related narrative text Each entry should have a text reference that is linked to the narrative text in the section.This is partially related to the comment above, but the wording in the Rubric and Description should match. There is a difference between "has to be" and "should have" that implies different levels of necessity. I suggest that the wording between related pairs are of the same "strength".entry/textReferenceBlock Vote 2Propose dispo to commenterNot persuasive with modWill modify text to: “Where a link between the narrative (section.text) and coded clinical data (entry) exists, the section.text must conceptually align with the meaning of the code it links with.” (aka, the code system display name). Will add one or more examples of "conceptually aligned" and "not conceptually alignedGay/Calvin2200Craig NewmanAltarum
94SDRequired RubricProblems8A-SEffectiveDate/Time elements have the right time and time zone offsets - This should be removed.It's not clear what "This should be removed" means. Should the whole row be removed? Please clarify.effectiveTimeBlock Vote 3PersuasiveThis text will be removed. Time and time zone offset rubrics and effectiveTime rubrics will all be aligned with each other as appropriate and will align with description in the recently published companion guideGay/Matt1900Craig NewmanAltarum
95SDRequired RubricMedications11A-TC-CDA medication lists should contain medications coded as RxNorm Semantic Clinical Drugs, Semantic Branded Drugs, and packs. This means prescribable products on the level of 'loratadine 10mg oral tabletC-CDA medication lists should contain medications coded as RxNorm Semantic Clinical Drugs, Semantic Branded Drugs, and packs. This means prescribable products on the level of 'loratadine 10mg oral tablet'Missing the closing quotation mark at the very end.Block Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Craig NewmanAltarum
96SDRequired RubricMedications12A-STwo Rubrics don't have a Description. Either a description should be added or some explanation should be provided as to why they don't have a description (so folks know they weren't accidentally omitted).FormattingBlock Vote 3Persuasive with modThis will be addressed with the planned format changes reqested by Ben Fleissner and KP Sethi and agreed to by the WG. This reformatting was draft designed and approved at the May WG and when reconciliation is done and we are prepping to publish we will present formalized format Gay/Matt1900Craig NewmanAltarum
97SDRequired RubricMedications12A-TWhen Medication status is active the high time should be in the future relative to the document generation date or the effectiveTime/high could be not presentWhen Medication status is active the high time should be in the future relative to the document generation date or the effectiveTime/high should be not present"could" seems like it should be "should"Block Vote 1Persuasive with modUpdate: Change to "Should not be present"Matt Rahn/Austin Kreisler2200Craig NewmanAltarum
98SDRequired RubricMedications12A-TMachine readable should align with the narrativeMachine readable doseQuantity should align with the narrativeSomething is missing between "readable" and "should"Block Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Craig NewmanAltarum
99SDRequired RubricImmunizations13A-SEffectiveDate/low for historical events should be greater than one year prior to the patient's date of birth and effectiveTime/high less than the earliest of current time or patient's date of death.EffectiveDate/low for historical events should be greater than the patient's date of birth and effectiveTime/high less than the earliest of current time or patient's date of death.Somethings like allergies may happen in utero, but there are no immunizations that are given prior to birth. Standard practice in the immunization community is to verify that an immunization happens after the date of birth and not before (not even in a one year window before as currently documented). I suggest you remove that pre-birth window.LifespanBlock Vote 3Not persuasiveThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Matt1900Craig NewmanAltarum
100SDRequired RubricSocial History14A-SSocial History elements are often less precise. Does the word "elements" refer specifically to portions of a CDA document or to the actual events (there isn't a specific time that a patient became homeless)? This could use some clarification as to what you are trying to say. effectiveTimeBlock Vote 3PersuasiveClarifying text will be added. Time and time zone offset rubrics and effectiveTime rubrics will all be aligned with each other as appropriate and will align with description in the recently published companion guideGay/Matt1900Craig NewmanAltarum
101SDRequired RubricSocial History14A-SDo not over specify the precision. For e.g. if the time is being defaulted to 000000 for hours, minutes and seconds for multiple entries it might be worth checking if the data was entered properly.Is the intent of the first sentence to say that a default time (like 000000) should not be included in the CDA value? Or that someone recording the data shouldn't try and "guess" a time that the social history applies to? Is the recommendation just to send a date (with no time) if a time is not definitively known? Or are you trying to say something else? Some clarification would be good. As well, many places use "For e.g.", this should probably be either "e.g." or "For example,"effectiveTimeBlock Vote 3PersuasiveClarifying testable text will be added. Time and time zone offset rubrics and effectiveTime rubrics will all be aligned with each other as appropriate and will align with description in the recently published companion guide "e.g." throughout will be tech edited to be formatted correctlyGay/Matt1900Craig NewmanAltarum
102SDRequired RubricLab Results 16A-TThere is an empty row that should be removedBlock Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Craig NewmanAltarum
103SDRequired RubricVital Signs17A-SNote: Organization should consider taking points away if it fails more than once as there’s a chance someone input 12:00:00 and it failsIt's not clear what this is trying to say. Who is the "organization"? Is this the tool? And the last part of the sentence doesn't make sense to me. Please reword.effectiveTimeBlock Vote 3PersuasiveThis text will be removed. Clarifying testable text will be added. Time and time zone offset rubrics and effectiveTime rubrics will all be aligned with each other as appropriate and will align with description in the recently published companion guideGay/Matt1900Craig NewmanAltarum
104SDRequired RubricVital Signs19A-SThe BMI rubric is missing a Description. I suggest it be added (or at least have an indication that a description is purposely not being included)BMIBlock Vote 3PersuasiveWe will clarify the rubric: If height and weight are present, the BMI value shall equal the patient’s weight in kilograms divided by the patient’s height in meters squared.Gay/Matt1900Craig NewmanAltarum
105SDRequired RubricVital Signs19A-TVital signs and results should use a LOINC CodeThis line seems to be duplicated (one without a Description), the second instance should be removed.Block Vote 1PersuasiveUpdate. Will remove.Matt Rahn/Austin Kreisler2200Craig NewmanAltarum
106SDRequired RubricGoals20A-SIf there’s a goal you must be able to tell what health concern(s) the goal is related to (Care Plan Document Type specific rubric for now, but will throw a warning for CCD, Referral Note, Progress Note and Discharge Summary - may ding for all document templates in the future)Avoid the use of "you" as you're not talking to the reader or developer. As well, the text in the parentheses doesn't make sense to me. Please reword and clarify this description to bring more in line with other lines. This same comment applies to the second Goals related requirement linking interventions to goals.Formatting - Testable statementsBlock Vote 3Persuasive1) We will correct grammar. 2) The rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroupGay/Matt1900Craig NewmanAltarum
107SDRequired RubricGoals20A-TIt looks like there are two lines associated with the Goals section (goal must relate to a health concern and each intervention must related to a goal) but in the Section/Entry/Header, there is an extra horizontal line between the two lines making it look like there is only a single "goals" line and then a line unrelated to any Section.Block Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Craig NewmanAltarum
108SDRequired RubricGoals20A-TAll Template Ids should be Valid for C-CDA and Supplemental IGs. If there is a valid template ID, but doesn’t align with above then provide an Informational message saying it’s an unrecognized template ID.All Template IDs should be valid for C-CDA and Supplemental IGs. If there is a valid template ID, but doesn’t align with above then provide an Informational message saying it’s an unrecognized template ID.Inconsistent capitalizations with "IDs" and "valid"Block Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Craig NewmanAltarum
109SDRequired RubricGoals20A-TInstance Identifiers should be unique for distinct acts. Encounters could have same ids when referencing the same encounter.Instance Identifiers should be unique for distinct acts. Encounters could have same IDs when referencing the same encounter.Inconsistent capitalizations with "IDs"Block Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Craig NewmanAltarum
110SDInformational RubricMedications21A-SThe Medications line is missing the Description, a Description should be added (or at least explicitly called out as not having one)Formatting - Testable statementsBlock Vote 3PersuasiveThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviewed with the workgroupGay/Matt1900Craig NewmanAltarum
111SD2.2A-SA whole lot of white space could be eliminated in col 1 (“Section/Entry/Header”) became a caption on the top of multiple individual section tables.FormattingBlock Vote 3PersuasiveThe overall guide format will change as part of publication. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviewed with the workgroupGay/Matt1900Emma JonesAllscriptsDaniel VentonDaniel.Venton@allscripts.com
112SD2.2A-QPerhaps it should be “Also if the time values are present without a time offset, the time may be interpreted incorrectly, hence time offsets should be specified as part of the time element.”Encounters (bottom page 5 et al) “Also if the time offsets are present without a time zone, the time may be interpreted incorrectly, hence time zones should be specified as part of the time element.” How does a person specify a time zone discretely from the time zone offset in a CDA USA Realm Date Time? There doesn’t seem to be a defined location for time zone. effectiveTimeBlock Vote 3Persuasive Clarifying testable text will be added. Time and time zone offset rubrics and effectiveTime rubrics will all be aligned with each other as appropriate and will align with description in the recently published companion guideGay/Matt1900Emma JonesAllscriptsDaniel VentonDaniel.Venton@allscripts.com
113SD2.28A-QSection 2.2 Problems (page 8) “EffectiveDate/Time elements have the right time and time zone offsets – This should be removed.” If the rule should be removed, why isn’t it removed OR is the “This should be removed” clause the part that should be removed?effectiveTimeBlock Vote 3PersuasiveThis text will be removed. Clarifying testable text will be added. Time and time zone offset rubrics and effectiveTime rubrics will all be aligned with each other as appropriate and will align with description in the recently published companion guideGay/Matt1900Emma JonesAllscriptsDaniel VentonDaniel.Venton@allscripts.com
114SD2.2A-QAllergies - Allergen representation is correct Description: The narrative name of the Allergen should represent the conceptual meaning of the code in the entryHow will this be validated? Please include how this will be accomplished so vendors are able to support implementations. entry/textReferenceBlock Vote 3Persuasive with modWill add clarity and keep this rubric: Allergen = in <templateId root="2.16.840.1.113883.10.20.22.4.7"/> : entryRelationship/observation/participant/participantRole/playingEntity/code/@code This @code's meaning must conceptually align with the referenced text Will add one or more examples of "conceptually aligned" and "not conceptually aligned"Gay/Matt1900Emma JonesAllscripts
115SD2.2A-QAllergies - Author entry includes a last modified date Description: Author entry must include at least a timestamp with information of the last modified date and be present within the Allergies entry, which could be at the concern or observation level.Is there a difference between author time and last modified date? If so, please explain and indicate how the CDA template constructs will differentiate. Author TimeBlock Vote 4Persuasive with modThere is no reference to "Last Modified" in the C-CDA IG. The intent of this rubric is to provided information that can be interpreted as the the last time a clinician addressed or noted the allergy and to prevent sending of null values in the time attribute - We will rewite the rubric: When sending an Allergy statement, either the Allergy Concern Act OR the Allergy - Intolerance Observation SHALL contain the Author Participation template :2.16.840.1.113883.10.20.22.4.119 which SHALL contain author/time which SHALL NOT be nulled.Gay/Matt2200Emma JonesAllscripts
116SD2.210A-QProblems - The Problem narrative representation should be correct Description: The narrative name of the Problem should represent the meaning of the code in the Problem Observation valueHow will this be validated? Please include how this will be accomplished so vendors are able to support implementations. DisplayName and Code allignmentBlock Vote 4PersuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error Gay/Matt2200Emma JonesAllscripts
117SD2.211A-QProblems - Author entry includes a last modified date and be present in the Problems entry Description: Author entry must include the most recent author with at least a timestamp with information of the last modified date and be present within the Problems entry, which could be at the concern or observation level.Please provide clarification between author time and last modified time. Please provide distinction between where this applicable timestamps are expected - on the problem concern or the problem observation template?Author TimeBlock Vote 4Persuasive with modThere is no reference to "Last Modified" in the C-CDA IG. The intent of this rubric is to provided information that can be interpreted as the the last time a clinician addressed or noted the problem and to prevent sending of null values in the time attribute - We will rewite the rubric: When sending a Problem Observation, the problem Observation SHALL contain the Author Participation template :2.16.840.1.113883.10.20.22.4.119 which SHALL contain author/time which SHALL NOT be nulled.Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
118SD2.211Problems - Narrative name of the problem should relate to the meaning of the code in the value Description: The narrative name of the Problem should represent the meaning of the code in the Problem Observation valueHow will this be validated? Please include how this will be accomplished so vendors are able to support implementations. DisplayName and Code allignmentBlock Vote 4PersuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
119SD2.211A-CMedications - Immunizations should be represented in the Immunizations section. Description: Immunizations should be recorded using the Section Code 11369-6 within the document.What about planned immunizations? Also, Immunizations are in the intervention section. Please fix description of account for immunizations when not in the immunization section. RWM - immunizations in immunization sectionWhat is the intent of this criteria?Persuasive with modAmend Rubric: In CCD and “Encounter Summaries” (Discharge Summary, Progress Note, H and P etc.) Administered immunizations SHALL be recorded in the Immunization Section. Future (orders or requests) for immunization (Planned) should be recorded in Plan section In Care Plan document both performed and future (orders or request) immunizations SHALL be recorded in the Intervention sectionLisa/Gay2200Emma JonesAllscriptsemma.jones@allscripts.com
120SD2.211A-CMedications - Substance administration effectiveTime should match the narrative Desctiption: The Substance administration/effectiveTime @xsi:type = pivl should agree with the Free Text Sig information.How will this be validated? Please include how this will be accomplished so vendors are able to support implementations. Free text sigBlock Vote 4PersuasiveWhile we agree that this would be difficult and even inappropriate, for vendors to enforce restrictions on free text sig, 1) conflict checking could be developed and implemented 2) Even if conflict checking would be too difficult to implement for a vendor, the intent of this rubric is to encourage proper clinical documentation by the end user. “Poor” scorecard grades related to this can be attributed to the clinical user as opposed to the vendor. We will add clarifying text with this caveat and suggest tools provide the same caveat.Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
121SD2.211A-CMedications - Substance administration effectiveTime Description: The Substance administration/effectiveTime @institution specified should agree with the Free Text Sig information.How will this be validated? Please include how this will be accomplished so vendors are able to support implementations. Free text sigBlock Vote 4Not persuasive with modWhile we agree that this would be difficult and even inappropriate, for vendors to enforce restrictions on free text sig, 1) conflict checking could be developed and implemented 2) Even if conflict checking would be too difficult to implement for a vendor, the intent of this rubric is to encourage proper clinical documentation by the end user. “Poor” scorecard grades related to this can be attributed to the clinical user as opposed to the vendor. We will add clarifying text with this caveat and suggest tools provide the same caveat.Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
122SD2.212A-QMedications - The Author should include a timestamp and modified date in the Medication Activity entry Description: Author entry must include at least a timestamp with information of the last modified date and be present within the Medication Activity entry.Is there a difference between author time and last modified date? If so, please explain and indicate how the CDA template constructs will differentiate. Author TimeBlock Vote 4Persuasive with modThere is no reference to "Last Modified" in the C-CDA IG. The intent of this rubric is to provided information that can be interpreted as the the last time a clinician addressed or noted the Medication and to prevent sending of null values in the time attribute - We will rewite the rubric: When sending a Medication Activity, the Sustance Administation SHALL contain the Author Participation template :2.16.840.1.113883.10.20.22.4.119 which SHALL contain author/time which SHALL NOT be nulled.Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
123SD2.212A-QMedications - Name of the drug should agree with the coded entry Description: The narrative name of the drug should represent the conceptual meaning of the code in the entryHow will this be validated? Please include how this will be accomplished so vendors are able to support implementations. DisplayName and Code allignmentBlock Vote 4PersuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
124SD2.212A-CMedications - The substance administration/route code should reconcile with the medication consumablePlease provide description of what this means. Route CodeBlock Vote 4Persuasive with mod CHANGE TO WARNING ONLY WITH THE FOLLOWING CLARIFIED RULE: If the manufacturedMaterial.code RxNorm code is term type that includes dose form (SCDF, SCDG, SCD, GPCK, SBDF, SBDG, SBD, BPCK) than the sustanceAdministration.route.code and manufacturedMaterial.code should not conflictGay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
125SD2.212A-CMedications - The substance administration status code should not conflict with the medication status observationPlease provide description of what this means. Medication StatusBlock vote 4Not persuasive with modRemove this rubric all together, based on lack of implementer input and that (Medication Status Observation) template is not present in C-CDA R2.1 or since HITSP C32 Side Note: Consider a project to examine act Status vs clinical status in medications.Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
126SD2.212A-QMedications - Machine readable should align with the narrative Description: The machine readable doseQuantity should agree with the Free Text Sig informationHow will this be validated? Please include how this will be accomplished so vendors are able to support implementations. Free text sigBlock Vote 4Persuasive with modWhile we agree that this would be difficult and even inappropriate, for vendors to enforce restrictions on free text sig, 1) conflict checking could be developed and implemented 2) Even if conflict checking would be too difficult to implement for a vendor, the intent of this rubric is to encourage proper clinical documentation by the end user. “Poor” scorecard grades related to this can be attributed to the clinical user as opposed to the vendor. We will add clarifying text with this caveat and suggest tools provide the same caveat.Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
127SD22.213A-QImmunization - The narrative should align with the meaning of the coded entry Description: The narrative name of the Immunization should represent the concept meaning of the code in the entryHow will this be validated? Please include how this will be accomplished so vendors are able to support implementations. DisplayName and Code allignmentBlock Vote 4PersuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
128SD22.218A-SVital Signs - The Vital Sign Observation entries should use the right LOINC codes to represent the type of vital sign being capturedThe Vital Sign Observation entries should use the recommended LOINC codes to represent the type of vital sign being capturedLOINC VSBlock Vote 4Not persuasive with mod 1) We will edit rubric to clarify this is for the Vital sign category and the rubric intends to enforce the using of, minimally this Vital Sign Result Type Value set, and if NOT from this value set than code must be from LOINC 2) We will clarify that the lab result rubric "SHOULD" is specified for the LOINC being from the top 2000 labs (b/c base standard already binds SHOULD to LOINC). WILL ADD OR if rad from https://loinc.org/download/loincrsna-radiology-playbook-file/ Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
129SD22.219A-SVital signs and results should use a LOINC CodeThis is repetitive. Suggest removing one. LOINC VS and ResultsBlock Vote 4Persuasive with mod 1) We will edit rubric to clarify this is for the Vital sign category and the rubric intends to enforce the using of, minimally this Vital Sign Result Type Value set, and if NOT from this value set than code must be from LOINC 2) We will clarify that the lab result rubric "SHOULD" is specified for the LOINC being from the top 2000 labs (b/c base standard already binds SHOULD to LOINC). WILL ADD OR if rad from https://loinc.org/download/loincrsna-radiology-playbook-file/ Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
130SD22.219A-QGoals - Each goal must be related to a specific health concernDoes this apply to patient specific goals as well?GoalBlock Vote 4Considered - Question AnsweredYes - a patient's goal should have a related concernGay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
131SD22.321A-QMedications - The substance administration/route code must not conceptually conflict with the narrative sigHow will this be validated? Please include how this will be accomplished so vendors are able to support implementations. Free text sigBlock Vote 4Persuasive with modWhile we agree that this would be difficult and even inappropriate, for vendors to enforce restrictions on free text sig, 1) conflict checking could be developed and implemented 2) Even if conflict checking would be too difficult to implement for a vendor, the intent of this rubric is to encourage proper clinical documentation by the end user. “Poor” scorecard grades related to this can be attributed to the clinical user as opposed to the vendor. We will add clarifying text with this caveat and suggest tools provide the same caveat.Gay/Matt2200Emma JonesAllscriptsemma.jones@allscripts.com
132SDOverallNEGI think the industry will need to have examples representing the rubrics. We SDWG can discuss and gain consensus wrt the best formatBlock Vote 1PersuasiveExamples will be provided for applicable rubrics in the new proposed format agreed upon at the May Work group.Matt Rahn/Austin Kreisler2200Gay DolinIntelligent Medical Objects
133SD4A-SIn order for these rubric criteria to be more exposed, members of SDWG suggested it would be a good idea to put the rubric criteria through an Informative Ballot.In part it was also the vendor community during 2019 January IAT. It would be positive to note responsiveness to the ballot request coming from vendors supporting end users whose code may be impacted and more importantly will be interacting with the end users to insure higher quality data makes it into CDA documents.IntroBlock Vote 4PersuasiveWill add text noting the vendor community involvement and request for an informatve ballot during 2019 January IAT. Vendors sited a need to encourage the capturing of higher quality data that will lead to higher quality date in CDA documents.Gay/Matt2200George Dixon
134SD6A-SEffectiveDate/Times for historical events should be greater than the patient's date of birth and less than the earliest of current time or patient's date of death.EffectiveDate/Times for historical events should be greater than the patient's date of birth and less than the earliest of either document generation date or patient's date of death.Use of current time I'm assuming means document generation date, it might be for clear to state that where ever this expression is used. LifespanBlock Vote 4Not persuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. ------------ Rubric: EffectiveTime for patient events should be less than one year prior to the patient's date of birth and less than 90 days post mortumGay/Matt2200George Dixon
135SD6A-QCheck whether the encompassing encounter is present in all encounter based documents i.e. Discharge Summary, Referral Note, etc. (do not ding if using CCD/Care Plan)Thank you for the no ding on CCD and Care Plan. Does mention of Care Plan mean that Score Card will be supporting Care Plan documents with release of this Rubric update. If that is the case are there Care Plan specific Rubrics to be included? encompassingEncounterBlock Vote 4Considered - Question AnsweredYes - there are a handful of Care Plan related rubrics defined in the Informative guide. It is most likely that the Score Card wil include those.Gay/Matt2200George Dixon
136SD7A-SThe Display Names used by the structured data should conceptually align with the meaning of the codeThis statement is used across sections, we would appreciate information on how the conceptual alignment assessment will be handled? What is the range of leeway end user clients will have in their display name entries to support their needs. DisplayName and Code alignmentBlock Vote 4PersuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error Gay/Matt2200George Dixon
137SDA-SA definitions table would help clarify statements that are used across sections. E.g. the use of Conceptually Align, defining this once would apply to all sections where its used. FormattingBlock Vote 4Persuasive with modThe document will be reformatted in accordance with the style agreed upon at the May 2019 WGM. The new draft will be brought to SDWG for review prior to final full draft development. With the new "testable format: if it is deemed by the WG a definitions table would be beneficial one will be addedGay/Matt2200George Dixon
138SD8A-TEffectiveDate/Time elements have the right time and time zone offsets - This should be removed.Is the text "- This should be removed." intended to be here? Or does it pertain to removing the rubric entirely? Block Vote 1PersuasiveText should be "EffectiveDate/Time elements have the right time and time zone offsets if the precision is proposed to the minute (or more specific). In additon we will be sure this aligns with the corresponding guidance given in the companion guideMatt Rahn/Austin Kreisler2200George Dixon
139SD10A-QNarrative name of the problem should relate to the meaning of the code in the valueIs this the same as "Conceptual alignment"? If it is, then the same language should be used. DisplayName and Code allignmentBlock Vote 4PersuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error Gay/Matt2200George Dixon
140SD16A-TBlank RowIs this a missing rubric or just needs to be deleted? Block Vote 1See 102PersuasiveDuplicate - See 102Matt Rahn/Austin Kreisler2200George Dixon
141SD17A-QNote: Organization should consider taking points away if it fails more than once as there’s a chance someone input 12:00:00 and it failsThis is not clear. What organization (ONC/Scorecard team)? Is the example that someone intended midnight so no ding unless it shows up repeatedly then its not intentional? Is this a note to self or request for input? Input, yes start dinging if its repeated within same document. effectiveTimeBlock Vote 4PersuasiveThis text will be removed. Clarifying testable text will be added. Time and time zone offset rubrics and effectiveTime rubrics will all be aligned with each other as appropriate and will align with description in the recently published companion guideGay/Matt2200George Dixon
142SD18A-QEach of the vital sign observation present in the document should use the recommended LOINC codes to represent the vital signHow will Scorecard handle the Head Circumference errata change to add a non measurement specific HC code. Will both be acceptable to cover historic data in systems? Vital sign - LOINC - HCBlock Vote 4Considered - Question AnsweredSee errata: https://www.hl7.org/dstucomments/showdetail.cfm?dstuid=168 With respect to the Head circumference LOINC code: Systems implementing rubrics SHALL allow the methodless code:"9843-4 Head Occipital-frontal circumference" in addition to the method specific code: 8287-5 Head Occipital-frontal circumference by Tape measure"Gay/Matt2200George Dixon
143SD19A-TVital signs and results should use a LOINC CodeNo description - this is a duplicate name entry for rubric - remove. Block Vote 1See 105PersuasiveDuplicate - See 105Matt Rahn/Austin Kreisler2200George Dixon
144SD19NEGEach goal must be related to a specific health concernOr problem. Goals are appropriate for existing problems. Persuasive with modIn a care plan document you must have a reference from a goal to the health concern For all other Document Types when there is a GoalObservation entry it should have a reference from the goal to a health concern OR problem2019-09-18Matt Rahn/Gay Dolin1400George Dixon
145SD21A-SInformational Rubric Table Consistent table width please. For that matter smaller right margin in document will shorten length of document. FormattingBlock Vote 2Persuasive with modWe will improve formatting of tables that remain given comments that have asked for a new format that may eliminate most tables.Gay/Calvin2200George Dixon
146SD21A-QAll problem codes should be expressed with core subset of SNOMED codesIs it acceptable to have SNOMED entered as translation code. ICD10 is common. ProblemTranslationCodesBlock Vote 4Considered - Question AnsweredA SNOMED CT code from the Problem Value set SHALL be in observation/value. Code from other code systems (such as ICD 10, or local codes may be in Translation (Add link to vocab page policy), additionaly, more specific SNOMED codes could also be present. ----- In addition, this rubric must be testableGay/Matt2200George Dixon
1472.27NEGThe Display Names used by the structured data should conceptually align with the meaning of the code. The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be optimized, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. Block Vote 1Persuasive with modAll of the statements that say the narrative needs to align with meaning of the code and they will be stated in the same manner so the wording will be consistent throughout. We agree this is important for semantic interoperabilityMatt Rahn/Austin Kreisler2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1482.27NEGEach Entry has to be linked to a related narrative test. The VHIE DQ team understands that the narrative has usefulness for human readability. When the data is available as narrative and not in the structured, the semantic interoperability is compromised. The recommendation is to educate all enterprises of the patient safety risk by not populating both the narrative and the structured.Block Vote 1Persuasive with modThe intent with the testable criteria is that the narrative does not conflict with the entry.Matt Rahn/Austin Kreisler2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1492.27NEGAllergyObservation entry has a reaction - The VHIE DQ Team is aware of the wide variation in Best Practice as to capturing the allergy information. The clinical intention of the communication exchange can be compromised with incomplete data capture and population. The VHIE DQ Team recommends working closely with clinical specialties and clinician organizations to define a tight set of data elements that can clearly and safely communicate the allergy data, thus supporting the formation of a knowledge exchange between the clinicians. This includes the allergen, Verify Date, the reaction and the severity with all of the corresponding code and code systems. If the data is unavailable, then the constraint can be defined f or a default date. The development of educational webinars with national organizations, such as The Sequoia Project, is key to developing interdisciplinary understanding of the interoperability challenges.Allergy - VHIEBlock Vote 4Not relatedWhile true statements wrt the importance of quality allergy data, the request is out of scope for this Informative Rubric GuideGay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1502.27NEGAllergyObservation entry has a reaction The VHIE DQ Team is aware of the wide variation in Best Practice as to capturing the allergy information. The clinical intention of the communication exchange can be compromised with incomplete data capture and population. The VHIE DQ Team recommends working closely with clinical specialties and clinician organizations to define a tight set of data elements that can clearly and safely communicate the allergy data, thus supporting the formation of a knowledge exchange between the clinicians. This includes the allergen, Verify Date, the reaction and the severity with all of the corresponding code and code systems. If the data is unavailable, then the constraint can be defined f or a default date. The development of educational webinars with national organizations, such as The Sequoia Project, is key to developing interdisciplinary understanding of the interoperability challenges.Allergy - VHIEBlock Vote 4Not relatedWhile true statements wrt the importance of quality allergy data, the request is out of scope for this Informative Rubric GuideGay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1512.27NEGThe Display Names used by the structured data should conceptually align with the meaning of the code - The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. Display Name - add textBlock Vote 4Not persuasive with modThe base standard already requires code and code system wherever a code is required.. This rubric is wrt the display name. If code/displayName is present, then the display name must be the preferred name of the owning code system. All of these rubrics will be rewitten in a testable format: xxx The rest of the comment is out of scope for this Informative guideGay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1522.28NEGAllergies should be structured with the correct code systems The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. displayNamesBlock Vote 4Not persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1532.29NEGThe Display Names used by the structured data should conceptually align with the meaning of the code. The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. dispayNamesBlock Vote 4Not persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1542.210NEGMedications effective/time should minimally be represented to the day, but should reflect more specific time when such time is available (e.g., reflecting hospital MAR time specificity) The VHIE Data Quality Team agrees. The VHIE Data Quality Team recommends that the more specific time also aligns with the data element that captures the visit type of the event (e.g. inpatient, outpatient). We have observed that the visit type impact is critical in some instances for the communication of the clinical intent. An example would be that the Emergency room visit may start an intravenous fluid after an initial loading dose with a high administration rate and then tapered to a slower administration rate, but dependent on the application architecture that information may not be clearly communicated to the clinical staff if the patient is then admitted as an outpatient. Block Vote 4Not persuasive with modRemove rubric or change it to be in alliance with with other effective time rubric descriptions and proper formatting of effectiveTime ".....more specific time also aligns with the data element that captures the visit type of the event (e.g. inpatient, outpatient). " is an out of scope ruleGay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1552.211NEGThe Display Names used by the structured data should conceptually align with the meaning of the code. The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Disp The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. displayNamesBlock Vote 4Not persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1562.211NEGMedications should be coded with RxNorm SCD, SBD, GPCK, or BPCPK codes The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE Data Quality Team has done analysis on over 200 Partners Production data and observations are widely varied. The multitude of code systems make semantic interoperability difficult. The NDF-RT is also used frequently by a variety of stakeholders. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The required data elements include the medication generic name, dose form, dose strength and Unit of measure and the order route. Note that the Order route is not necessarily the default Product Route (e.g. an IV can be used to formulate a pediatric suspension). The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. displayNamesBlock Vote 4Not persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1572.212NEGMedications should have Free Text Sig entry. The VHIE Data Quality team agrees that there should be a Free Text Sig entry. The VHIE Data Quality team recommends that the individual data elements that formulate a SIG need to be included. We recognize that SIG is often a proprietary or local code system, but the individual data elements that are part of the database architecture are very valuable data elements. The stakeholder specific SIG is not the level of semantic interoperability. By exposing the application specific data elements that are used to formulate the local SIG values, the situation can become more semantically interoperable.Free text sigBlock Vote 4Persuasive with modThe Rubric Stands as: Medications should have Free Text Sig entry. And Medications should have a free text sig entry to communicate medication instructions to providers and patients. The work group does not see additional asks in this comment. Also Note previously agreed upon related dispo: While we agree that this would be difficult and even inappropriate, for vendors to enforce restrictions on free text sig, 1) conflict checking could be developed and implemented 2) Even if conflict checking would be too difficult to implement for a vendor, the intent of this rubric is to encourage proper clinical documentation by the end user. “Poor” scorecard grades related to this can be attributed to the clinical user as opposed to the vendor. We will add clarifying text with this caveat and suggest tools provide the same caveat.Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1582.212NEGThe substance administration status code should not conflict with the medication status observation The VHIE Data Quality team agrees that the status code should not be in conflict with the medication status observation. The VHIE Data Quality Team recommends that additional clarifications of the status definitions are required. Our analysis has observed that there is a need to further clarify each of the medication status values and require tight adherence. Without the clear clinical intention being communicated, the patient safety risk during semantic interoperability increases.Medication Status ObervarionBlock Vote 4Not persuasive with modPreviously agrred upon dispo (comment 71): Remove this rubric all together, based on lack of implementer input and that (Medication Status Observation) template is not present in C-CDA R2.1 or since HITSP C32 Side Note: Consider a project to examine act Status vs clinical status in medications. Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1592.213NEGThe Display Names used by the structured data should conceptually align with the meaning of the code The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. displayNamesBlock Vote 4Not persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1602.214NEGEffectiveDate/Time elements have the right time and time zone offsets if the precision is proposed to the minute. The VHIE Data Quality team agrees that there needs to be a Best Practice attempt to capture the Social History Effective date. If it cannot be established, then a default value definition needs to be defined. For example, if the patient identities it was five years ago, then the default might be 01/01/(current year – 5 years).effectiveTimeBlock Vote 4Not persuasive with modPreviously agreed to dispo (comment 94 and many others): Clarifying text will be added. Time and time zone offset rubrics and effectiveTime rubrics will all be aligned with each other as appropriate and will align with description in the recently published companion guideGay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1612.214NEGEffectiveDate/Times for all historical activities should be within the lifespan on the patient. The VHIE Data Quality team has a question about the algorithm. Is the “greater than one ear prior to the patient’s date of birth” because of the concept of gestational age?LifespanBlock Vote 4Persuasive with modPreviously agreed to dispo (comment 78 and many others): There may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. NOTE: 1) ALSO, WRT THIS TEXT, "EffectiveDate/low for historical events should be greater than one year prior to the patient's date of birth" CHANGE TO, " EffectiveDate/low for historical events should be LESS than one year prior to the patient's date of birth 2) and 90 days post mortum WHEREVER THIS RUBRIC IS STATED - ALIGN TEXTGay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1622.214NEG The Display Names used by the structured data should conceptually align with the meaning of the code. The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. displayNamesBlock Vote 4Not persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1632.215NEGBirth Sex has to be recorded as a social history observation. The VHIE Data Quality Team has a question about defining “pronouns” that are available to the non-clinical staff who may greet the patients. There is a Demographics gender and a birth sex. Is there also the patient self identified gender? Birth sexBlock Vote 4Not persuasiveIn the current C-CDA standard on;y AdministrativeGender (recorded in the header) and Birth Sex are defined data elememts. This rubric is to enforce captire of the somewhat more clinically valuable birth sex and have it captured in the socila history section, so systems know where to look for it. Note that there is a "Gender Harmony" Project sponsored by the HL7 vocabulary workgroup whose goal is to workout out the correct terms used to express all the concerns around both gender and sex. We encourage your involvement.Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1642.216NEGThe Display Names used by the structured data should conceptually align with the meaning of the code. The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. displayNamesNot persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1652.217NEGThe Display Names used by the structured data should conceptually align with the meaning of the code. The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Disp The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. displayNamesBlock Vote 4Not persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1662.218NEGVital signs and results should use a LOINC Code. The VHIE Data Quality team agrees with using the LOINC code for Vital signs and results. The recommendation is that if the data element does not have a LOINC code, then it should not populate the Vital Signs. Our observations acknowledge that semantic interoperability is not well supported when inappropriate data populates the Vital signs and Results. The observation of Activities of Daily Living (ADL) populating the Vital Signs indicates that the data cannot be included in semantic interoperability or it will fail. This example has identified that there is ADL data available but it is not coded and therefore not available to the receiver during the data exchange. LOINC VS and ResultsBlock Vote 4Not persuasive with modPreviously agreed upon dispo: (comment 83 etc): The actual rubric is: A LOINC Code must be used when coding vital signs and results. 1) There are duplicate rows under the "Vital signs" category - we will remove one 2) The base standard has a SHOULD binding to LOINC in Results already (CONF:1198-7133) 3) A later "Informational" states lab results SHOULD be from LOINC and SHOULD be from the top 2000 LOINC Lab codes 4) Therefore, this rubric is either conflicting or misplaced (meant to be just Vital Signs?) 5) WRT Vital Signs, Vital Sign Result Type is a SHOULD binding to LOINC value set 6) Assuming this rubric is intended for Vital signs, and the rubric intends to enforce the using of, minimally this Vital Sign Result Type Value set, and if not from this value set than from LOINC --------------------------------------------- 1) We will edit rubric to clarify this is for the Vital sign category and the rubric intends to enforce the using of, minimally this Vital Sign Result Type Value set, and if NOT from this value set than code must be from LOINC 2) We will clarify that the lab result rubric "SHOULD" is specified for the LOINC being from the top 2000 labs (b/c base standard already binds SHOULD to LOINC). WILL ADD OR if rad from https://loinc.org/download/loincrsna-radiology-playbook-file/ Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1672.219 NEGThe Display Names used by the structured data should conceptually align with the meaning of the code. The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Disp The VHIE Data Quality (DQ) Team agrees that the display names need to align with meaning of the code/code system. This applies to all of the Display Name Rubrics in this document. The VHIE DQ Team recognizes the enormous changes in interoperability, including the priority for semantic interoperability. The challenge of semantic interoperability to communicate the “clinical intention” between two clinicians using interoperability requires that the risks need to be limited. The VHIE DQ Team realizes that patient safety risks are highest during transition. With data interoperability, the transition is when two healthcare entities attempt interoperability. For semantic interoperability to be enabled, we suggest that additional constraints require that every code and code system is populated. If the data is unavailable, then every code and code system would have a default entry reflecting that the data is unavailable. Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperabilitydisplayNamesBlock Vote 4Not persuasive with modIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error The Rubric Guide's intent is not to add NEW backwards incompatable rules such as is suggested by this comment with respect "Limiting the number of code and code systems to a primary and a secondary will also more effectively support semantic interoperability. "Gay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1682.219NEGProcedures should be structured with the correct code system The VHIE Data Quality team recommends that the data elements that are required for semantic interoperability be clarified and defined as MUST. ProceduresBlock Vote 4PersuasiveRubric will be rewitten (as all rubrics will be) to be testable: Procedures SHALL be coded with CPT, CDT-2, ICD-9, ICD-10, SNOMED, HCPCS or LOINCGay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1692.220NEGEach intervention must relate to a specific goal The VHIE Data Quality team recommends that Clinical documents, in particular Nursing Notes, be standardized and contain discrete data to augment the narrative. Is there a WG devoted to the Nursing Notes and other Clinical Notes? In order to support Semantic Interoperability, the more structured note can still be viewed as a narrative. An example would be the game “Mad Libs” where the text is defined around a series of requested data elements to populate the narrative note.Intervention/GoalsBlock Vote 4Not persuasive with modThis rubric is primarily focused on the relating of Goals and intervention in a Care Plan Document Type. This Rubric will be rewitten (as all rubrics will be) to be testable: Something like: If an Intervention Act (V2) [act: identifier urn:hl7ii:2.16.840.1.113883.10.20.22.4.131:2015-08-01 is present, then it must contain either an Entry Reference [act: identifier urn:oid:2.16.840.1.113883.10.20.22.4.122 2015-08-01 which points to the ID of the intervention's related goal or be contained by or contain its related Goal Observation [observation: identifier urn:oid:2.16.840.1.113883.10.20.22.4.121 using the REFR act realtionship type In document Types other than Care Plan - this will only be a warningGay/Matt2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1702.321NEGLab results should be expressed with preferred LOINC codes which are published as the top 2000 LOINC codes from Regenstrief. The VHIE Data Quality Team agrees with LOINC for Lab tests. The VHIE Data Quality team is aware that certain aspects of Resulting Labs may not be sufficiently granular – and sometimes results are reported in SNOMED. Is there a working group for this topic? Block Vote 2Not persuasiveOut of scope - LOINC is recommended (SHOULD) in the base standard and for labs, and by the EHR incentive programsthe the top 2000 LOINC for labs is recommended by the Rubric. SNOMED for lab observables/procedures in the based standard nor sited as a lab vocabulary in the EHR incentive programsGay/Calvin2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1712.321A-AAll problem codes should be expressed with core subset of SNOMED codes The VHIE Data Quality Team agrees.Block Vote 2Considered - No action requiredNo Action needed.Gay/Calvin2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
1722.321NEGThe substance administration/route code must not conceptually conflict with the narrative sig The VHIE Data Quality Team is in agreement with the recognition that there are medication orders which utilize a product (with a default administration route) with a different order administration route.Block Vote 2Not persuasiveNo Action needed. The commenter agrees with a listed rubric. This statement already exists as a listed rubric, "The substance administration/route code must not conceptually conflict with the narrative sig " A negative vote is not appropriate for this comment.Gay/Calvin2200Greg Staudenmaier US Department of Veterans AffairsSandi Mitchellsandi.mitchell@jpsys.com
173SDNEGRequired – All tools adopting this criteria should throw an error.I agree with this sentiment. However, the way a majority of the rubric requirements are written, its impossible to throw an error because the rubric is written in a way that cannot be tested. E.g. The Problem narrative representation should be correct. The description sometimes helps make things a little clearer but not always. I suggest that the rubric make note of where things need to be rigrous YesBlock Vote 2PersuasiveRubric will be rewritten for testabilityGay/Calvin2200Kanwarpreet SethiLantana Consulting Group, Inc. KP Sethikp.sethi@lantanagroup.com
174SDNEGOverall commentThe way the rubric is written is inconsistent. Eg. In some places the following language is used: Machine readable should align with the narrative. In other places it says: The narrative should align with the meaning of the coded entry To be used as a framework to throw errors etc, these need to be consistentYesBlock Vote 1PersuasiveUpdate all to: The narrative should align with the meaning of the coded entryMatt Rahn/Austin Kreisler2200Kanwarpreet SethiLantana Consulting Group, Inc. KP Sethikp.sethi@lantanagroup.com
175SDA-SGeneralSuggest a general framework defined above so that the basic stuff doesn't need to be repeated for each section. E.g The Display Names used by the structured data should conceptually align with the meaning of the code. This is a common one that is often repeated. Suggest these are pulled out into a general rubric that is true for all sections + entries in C-CDA. Similarly dates/effectiveTimes would also follow a general guidance. This would make reading the rubric and implementing it much easierFormattingDiscuss on a callPersuasiveWill reformat to have a general rule chapter. A revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviewed with the workgroupGay/Calvin1900Kanwarpreet SethiLantana Consulting Group, Inc. KP Sethikp.sethi@lantanagroup.com
176SD1OverviewNEGThis set of Rubric should not include conformances that are already SHALL constraints in the associated Implementation Guide. It should focus on constraints that are a SHOULD in the IG, but the community agrees the constraint should be tighter (a SHALL) to promote interoperability. And it can focus on constraints in the IG that are a MAY, but the community agrees the constraint should be tighter (a SHALL) to promote interoperability. When a rubric turns a SHOULD constraint in the IG into a SHALL, the rubric should be treated as a Best Practice Rubric. When a rubric turns a MAY constraint in the IG into a SHALL, the rubric should be treated as a Candidate Rubric. When a rubric establishes a constraint to utilize an aspect of the Base CDA standard not yet called as a constraint in the IG, the rubric should be considered a Candidatee rubric.YesNew HeurisitcPersuasive with modAgree to: This set of Rubric should not include conformances that are already SHALL constraints in the associated Implementation Guide. New heuristic with respect to progress from canditate to best practice is out of scopeGay/Matt1400Lisa R. NelsonMasMDLnelson@max.md
177SD1OverviewNEGThe hope is that the rubric will promote best practices by allowing providers and health IT developers to identify and resolve issues of C-CDA document data representation in their health IT systems thereby promoting interoperability and use of clinical data received in C-CDA documents.The hope is that the rubric will promote expansion of nationwide interoperability by allowing providers and health IT developers to identifying inconsistencies with data representation in C-CDA documents and proactively adopt, through these rubric, tighter constraints to eliminate the variability.YesBlock Vote 1Update descriptionPersuasive with modWill update to: The hope is that the rubric will promote expansion of nationwide interoperability by allowing providers and health IT developers to identify inconsistencies with data representation in C-CDA documents and proactively adopt tighter constraints to eliminate the variability.Matt Rahn/Austin Kreisler2200Lisa R. NelsonMasMDLnelson@max.md
178SD1OverviewNEGA subset of the rubric criteria are utilized to identify best practice tests and quantitative scoring criteria in the Office of the National Coordinator for Health IT (ONC) C-CDA Scorecard.Rubric criteria are utilized to identify where the implementation community using the C-CDA standard agrees the constraints need to be tighter and more specific in order to support interoperability.The biggest problem with the current approach is scoring algorithm used to determine what constitutes an A, B, C, D, etc. This aspect of the "scorecard" should be eliminated. The reeport produced for a tested document should be objective and simply report how the document performed against each test.The focus of the Rubric needs to shift away from being a "SCORECARD" in favor of being a tool that can be used to tell if an implementation is producing C-CDA documents that meet what the community agrees is needed for interoperability and for critical use cases such as Quality Measurement or Closed Loop Referrals, etc. Just like USCDI, the C-CDA Rubric needs to be viewed as both a set of criteria over and above C-CDA as well as a collaborative process that the implementer community drives foward.YesBlock Vote 2Persuasive with modWill update proposed wording, but the tooling is out of scope for this comment.Gay/Calvin2200Lisa R. NelsonMasMDLnelson@max.md
179SD1OverviewNEGThe ONC C-CDA Scorecard is designed to allow implementers insight into C-CDA implementations and highlights areas of improvement which can be made today to move the needle forward. The intent is to add these additional rubrics to the ONC Scorecard.The C-CDA Rubric process provides predictable, transparent, and collaborative process that highlights areas for improvement in the C-CDA specifications which can be made today and are needed to expand nationwide interoperability. Again, we should decouple the notion of defining the C-CDA Rubric from the use of the rubric in the ONC Scorecard tool. The rubric should be considered a resource that could be used by any organization to determine if the implementation of C-CDA (and the documents produced by that implementation) meet the best practices agreed to be needed for interoperability.YesReady to ImplementPersuasiveReword as suggestedMatt Rahn/Michael Clifton900Lisa R. NelsonMasMDLnelson@max.md
180SD1OverviewNEGn order for these rubric criteria to be more exposed, members of SDWG suggested it would be a good idea to put the rubric criteria through an Informative Ballot.n order for these rubric criteria to be more transparent and for the process to be more collaborative, the rubric criteria will utizie the HL7 Informative Ballot to establish and evolve the criteria.YesBlock Vote 1UpdatePersuasiveAgree with changeMatt Rahn/Austin Kreisler2200Lisa R. NelsonMasMDLnelson@max.md
181SD11.1A-SThere is an industry need for disparate systems to be able to communicate with each other.There is an industry need for disparate systems to exchange clinical information with each other.YesText clarificationBlock Vote 4Persuasive with modThere is an industry need for disparate systems to exchange information with each other.Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
182SD11.1NEGEnd users can use tools that utilize these rubric criteria to determine the quality of their C-CDA applications, leading to quality improvement discussions with their vendors. The Informative Ballot will help gain widespread consensus on the appropriateness of the rubric criteria.End users can utilize these rubric criteria to determine the quality of the C-CDA exchange documents produced by their applications. Adherence to the C-CDA rubric criteria will lead to quality improvement discussions between clinical information users system C-CDA document creators. The Informative Ballot will promote widespread consensus on the rubric criteria needed to expand interoperability.I think separate the process of extablishing a community-driven set of rubric criteria that drive expansion of interoperability from the idea of using the rubric in the ONC Scorecard. The rubric criteria should be available for any tool to employ. The rubric should be expressed in a way that support consistent use of the rubric across multiple tooling stacks.YesBlock Vote 1UpdatePersuasiveWill update proposed wordingMatt Rahn/Austin Kreisler2200Lisa R. NelsonMasMDLnelson@max.md
183SD11.1NEGRubric rules should be expressed using the very same constraint language as the C-CDA specification. Each Rubric Rule should include as part of its documentation the Constraint that it tightens in C-CDA. Some Rubric criteria will be broadly applied to a an element that effects all templates, like the text element of the act, so it may not be practical to site the related conformance statement id's in that case. Some Rubric may be new constraints that utilize the Base CDA model, in which case there would be no C-CDA constraint ID to reference. Rubric criteria should be modeled in the same constraint langage as C-CDA templates use when they are specific to a particular template. We need to move away from expressing the rubric in imprecise human prose. Making this change would make the rubric criteria more transparent and predictable.YesFormatting - Testable statementsDiscuss on a callPersuasive with modThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroupCalvin/Gay1900Lisa R. NelsonMasMDLnelson@max.md
184SD22.1NEGThe rubric criteria are a set of rules that go above and beyond EHR certification.The rubric criteria are a set of tighter constraints the implementer community agrees are needed to expand interoperability.I don't think you should bring EHR certification into this. Just stick to the relationship of Rubric Criteria to the C-CDA specification. The rubric are a set of tighter constraints the implementer community agrees are needed to expand interoperability.YesText clarificationBlock Vote 4Persuasive with modAdd: The rubric criteria are a set of tighter constraints then exist in C-CDA R2.1 that the implementer community agrees are needed to expand interoperability. Howver: We believe that we need to keep some type of statement so that implementers not aware of the purpose of the Rubric Informative guide and do not overinterpret as certification rules.Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
185SD22.1NEGThey are meant to be utilized in best practice testing tools to provide feedback to industry and help drive the EHR vendor community towards consistent implementation of the C-CDA standard.They are meant to be utilized in best practice testing tools to provide feedback about C-CDA exchange documents and if they adhere toindustry acknowledged best practices that support interoperability and valued use cases for clinical information exchange.They also are intended to help drive the EHR vendor community towards consistent implementation of the C-CDA standard.YesText clarificationBlock Vote 4PersuasiveWill modify text: They are meant to be utilized in best practice testing tools to provide feedback about C-CDA exchange documents and if they adhere to industry acknowledged best practices that support interoperability and valued use cases for clinical information exchange.They also are intended to help drive the EHR vendor community towards consistent implementation of the C-CDA standard.Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
186SD22.1NEGThere are two types of Rubric criteria identified: • Required – All tools adopting this criteria should throw an error. • Informational - All tools adopting this criteria should throw a warning, not an error.There are two types of Rubric criteria identified: • Emeging – These are SHOULD constraints in the C-CDA IG which get tested as SHALL criteria in the Rubric. Violation of Emerging criteria procude an error in tools that implement testing of the Rubric constraints. • Candidate - These are MAY constraints in the C-CDA IG or new constraints on the base CDA model which get tested as SHALL criteria in the Rubric. Violation of Emerging criteria procude an error in tools that implement testing of the Rubric constraints.I picked these two terms to align with notions from the proposed USCDI process. In the evolutionary process things (data elements or rubric criteria) go from not existing to existing as a recognized "Candidate". From there, as evolution continues, they become acknowledged as "Emergent". Eventually, once adopted into a standard, they become "Required" Note that Required criteria would have been included in the spec for C-CDA itself. The rubric should not repeat the conformance criterial aleady included as a SHALL in the C-CDA IG. "Validation" would already cover rules that are "Required". The Rubric is focused on raising the bar. These are test of tighter constraints not yet required in the C-CDA IG. YesNew HeurisiticNot relatedNew heuristic with respect to progress from canditate to best practice is out of scope WITHDRAWN BY LISA DEC 19 2019withdrawn 2019-Dec-19wwwLisa R. NelsonMasMDLnelson@max.md
187SD22.2NEGThe Rubric should be organized to align with the base C-CDA templates. First covering the Rubric for the header template in general. Next cover rubric for the header of each document type.There are some header rubric that need to be different for different types of documents. The rubric for a general type of document, like a discharge summary, needs to be applied to all document types in the value set that defines types of Discharge Summary documents. Same is true for each document type.YesFormattingBlock Vote 4Persuasive with modWill reformat to have a general rule chapter. A revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviewed with the workgroupGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
188SD22.2NEGThe rubric about narrative text linking and correspondence between the coded data and the narrative information should be handled following the section covering the rubric for headers.There are several rubric that address the need to confirm that the human readable narrative conveys the same semantic meaning as the coded data.YesFormatting - Testable statementsBlock Vote 4Persuasive with modThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroupGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
189SD22.2NEGEntry-level rubric should be specific to a particular entry template. Don’t use general categories, it is not clear enough what the expectation is. Use the real template and show the tighter constraints that are expected by the rubric.Again, rubric rules need to be "tooled" constaints, not human narrative descriptions. The descriptions are too imprecise.YesFormatting - Testable statementsBlock Vote 4Persuasive with modThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroupGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
190SD22.2NEGThis comment applies to every Rubric criteria that affects a data element that is of type date/time.For each and every effectiveTime data element where a Rubric criteria is proposed, the implementer community needs to agree the required level of precision and a computable constraint syntax needs to be developed to express that level of precision requirement for a dateTime data type both for the Date/Time and the Period options.This should be done in a way that works for FHIR data elements as well. We need a computable syntax for expressing the requirement for specificity from just a year all the way down to the seconds and if a timezone offset is required or not.YesFormatting - Testable statementsBlock Vote 4Persuasive with modThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroup. In addition, all effectiveTime statements will align with each other (if / when they need to repeat) and will align with the recenlty published C-CDA companion guideGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
191SDNEGPatient's alternative names such as birth name, previous name should exist in its own name element independent of the name element representing a legal name.Descriptions like this just are not precise enough. The criteria needs to be expressed more specifically using the actual attribute being constrained (use). This doesn't seem testable. What is the constraint to be tested. If the person doesn't have alternative names, of birth name, or previous name, it would not be wrong for these other names to not be present. this is more like guidance than a testable thing.Put guidance like this in the Companion Guide. It just isn't a testable constraint. What would it look like in the xml if a CDA document got this wrong? Syntactically you can’t get this wrong without the xml being non complient to CDA. This isn't a Rubric Criteria. You are not changing a SHOULD constraint to a SHALL or a MAY to a SHALL. You are just providing guidance on the use of the use attribute in the name tag.YesFormatting - Testable statementsBlock Vote 4Persuasive with modThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroup. Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
192SDNEGEffectiveDate/Times for all historical activities should be within the lifespan on the patientThe notion of "within the lifespan of the patient" needs to be specifically defined and agreed to be the community. I don't agree it should cover 1 year prior to birth and end at date of death. I believe it should span from date of birth to date of death. Edge cases for issues while in the womb or autopsies performed after death are so rare, we should handle those a very rare exceptions...the rule should not be opened up on account of such rare examples. YesLifespanBlock vote 4Not persuasive with modThere may be legitimate use cases for documenting activities in a note before birth or after death. For example, fetal surgery, where the institutions may maintain pre-birth charts and there may be death notes after death where postmortem care was provided, documented. However, these types of notes are not typically sent in C-CDA document types for transition of care. The intent of this rubric is to avoid communication of sloppy and erroneous time stamps. However, this rubric should be informational for the cases where such time stamps are legitimate. This rubric will generate a warning only. NOTE: 1) ALSO, WRT THIS TEXT, "EffectiveDate/low for historical events should be greater than one year prior to the patient's date of birth" CHANGE TO, " EffectiveDate/low for historical events should be LESS than one year prior to the patient's date of birth 2) and 90 days post death WHEREVER THIS RUBRIC IS STATED - ALIGN TEXTGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
193SDNEGCheck whether the encompassing encounter is present in all encounter based documents i.e. Discharge Summary, Referral Note, etc. (do not ding if using CCD/Care Plan)For C-CDA document types you need to very specifically define "encounter summary documents" to clarify which document type are which are not "encounter summaries". The list needs to enumerate all 12 types of C-CDA document and say if it is or is not an "encounter summary document".YesencompassingEncounterBlock Vote 4Persuasive with mod1. Clarify encompassingEncounterID Rubric to: Where encompassingEncounter is present in the C-CDA R2.1 header AND Encounter Activitie(s) are present in the body of the document, then the encompassingEncounter date/time and ID SHALL equal one of the encounter/IDs in one encounter activity in the body of the document 2. Remove this rubric: The encompassing encounter shall be present in all encounter based documents i.e. Discharge Summary, Referral Note, etc. (do not ding if using CCD/Care Plan) Note: In the C-CDA Standard: Consult Note: SHALL encompassingEncounter Discharge Summary: SHALL encompassingEncounter Progress Note: SHALL encompassingEncounter Referral Note: encompassingEncounter is not required Transfer Summary: encompassingEncounter is not required Care Plan: SHOULD encompassingEncounterGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
194SDNEGEach entry should have a text element with a reference that is linked to the corresponding narrative text in the section.text.Each templated act should have a text element with a reference that is linked to the corresponding narrative text in the section.text.The distinction is important an account of some entries being "compound entries" where a template contains a template. The compound entries need more linked text elements. A minimum of one per primary act in the template is needed.YeswithdrawnWithdrawnNot relatedLisa withdrew this commentwithdrawn 2019-Dec-19wwwwithdrawnLisa R. NelsonMasMDLnelson@max.md
195SDNEGEach of the code systems, value sets specified by the C-CDA IG refers back to standard terminologies like SNOMED-CT, LOINC, RxNorm, ICD9, ICD10. When codes from these code systems are used to represent structured data the short or long description assigned in the code system for the code should be used in the display name of the code element in the C-CDA documentA rubric constaint like this should be enumerated just once and applied everywhere a coded concept element is used.This is an overall constraint exectation that is much broader than an individual entry template. The code comes from a code system and it has a specific meaning in the context of that code system. This can't be changed. The Display Name is the meaning within the code system, included for the benefit of the humans. It can't be modified from what the code systems sets the code to mean.YesFormattingBlock Vote 4Persuasive with modThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroupGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
196SDNEGThe narrative name of the Allergen should represent the conceptual meaning of the code in the entryAll of the Rubric Constraints that would require NLP to validate should be moved into a separate section of the Rubric.It is not clear how this type of NLP-based rubric would be executed consistently across systems. I recommend removing NLP based Rubric until the NLP technology becomes more mainstream and consistency can be demonstrated across different NLP systems.YesDisplayName and Code allignmentBlock Vote 4Not persuasive with modPreviously agreed on comments at WG and in previous block votes agreed to keeo this rubric but clarify the text to: If DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
197SDNEGAllergies should be structured in UNII, NDF-RT, SNOMED or RxNormThis is a good example of why the Rubric rules need to be a machine generated set of constraints that build upon C-CDA Templates and Value Set definitions. This value set has changed an nolonger includes UNII.The Rubric rules can't be manually generated. They will get out of sync all the time. They need to be a layer on top of/Over the existing SD definition of the template being further constrained.YesFormatttingBlock Vote 4Not persuasive with modThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroupGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
198SDNEGThe problem observation value should not be set to the problem observation code (problem type value set)The concepts in the Problem Type Value Set are not in the Problem Value Set. If value set validation is happening correctly, this situation would not be valid to begin with.YesProblem type vs ProblemBlock Vote 4Not persuasive with modYou are mostly correct, but: 1) Its unlikely that folks have implemented value set validation correctly, completely nor kept up to date 2) If the snomed codes are usedin Problem type - if validiation rules due not exclude "Finding" then it,is in the value set. "55607006 Problem (finding)" is in the value set, etc 3) This may encourage systems to properly capture data enter by clinician (or develop rules to enforce entering of coded problems 4) This rubric will be written in a testable mannerGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
199SDNEGAuthor entry must include the most recent author with at least a timestamp with information of the last modified date and be present within the Problems entry, which could be at the concern or observation level.Author entry must include the most recent author with at least a timestamp with information of the last modified date and be present within the Problem Concern entry, which could be at the concern or observation level.There is no such thing as a Problems entry. Language like this is very problematic. Good example why the Rubric criteria needs to be built with a tool that uses the actual templates.YesAuthor TimeBlock Vote 4Persuasive with modThere is no reference to "Last Modified" in the C-CDA IG. The intent of this rubric is to provided information that can be interpreted as the the last time a clinician addressed or noted the problem and to prevent sending of null values in the time attribute - We will rewite the rubric: When sending a Problem Observation, the problem Observation SHALL contain the Author Participation template :2.16.840.1.113883.10.20.22.4.119 which SHALL contain author/time which SHALL NOT be nulled.Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
200SDNEGImmunizations should be represented in the Immunizations section. Immunizations should be recorded using the Section Code 11369-6 within the document.Don't mix immunization criteria in with Medication criteria.YesRWM - immunizations in immunization sectionWhat is the intent of this criteria?Persuasive with modAmend Rubric: In CCD and “Encounter Summaries” (Discharge Summary, Progress Note, H and P etc.) Administered immunizations SHALL be recorded in the Immunization Section. Future (orders or requests) for immunization (Planned) should be recorded in Plan section In Care Plan document both performed and future (orders or request) immunizations SHALL be recorded in the Intervention sectionLisa/Gay2200Lisa R. NelsonMasMDLnelson@max.md
201SDNEGSmoking status observation should be present. This is an observation with observation.code= 72166-2 Smoking status observation Template Id should be present in CCD and Referral Note.This should be a specific constraint with a SHALL in place of a prior SHOULD in the C-CDA Spec.YesFormatting - Testable statementsBlock Vote 4Persuasive with modThe rubrics will be reformatted and written as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroupGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
202SDNEGThe effectiveTime interval in the Result Organizer must encompass the effectiveTimes of the observations within the organizer.This should be framed the other way around. The effectiveTime of the component observations in an organizer should fall within the range of time specified for the Organizer in its effectiveTine. YesOrganizer effectiveTimeBlock Vote 4PersuasiveOK - rewite as suggested: The effectiveTime of the component observations in an organizer should fall within the range of time specified for the Organizer in its effectiveTine. Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
203SDNEGIf observation value is recorded as a PQ datatype and if present, the observation range should be coded as an “IVL_PQ” (a parse-able range high/low attributes instead of narrative text).Not clear what this means.YesReference rangeBlock Vote 4Persuasive with modWill add clarifying testable text: If a (result) observation value is a physical quantity ("PQ") (e.g. md/dL), its observation.value reference range shall be an physical quantity interval (“IVL_PQ” ) repesented with the same unit as its observation.value PQGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
204SDNEGThe recommended UCUM units should be used to represent the Vital Sign result values as part of the observation.Good example of the constraint already existing in C-CDA, it just needs to be a SHALL rather than a SHOULD in the Rubric.YesFormatting - Testable statementsBlock Vote 4PersuasiveWill adjust during the reformatting as testable statements but not with formal contraint language. The revised format style was agreed to at the May 2019 WGM. When we are readying to incorporate comments and reformat - the final version of the reformattting will be reviwed with the workgroupGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
205SDNEGIf there’s an intervention you must be able to tell what goal(s) the intervention is related to (Care Plan Document Type specific rubric for now, but will throw a warning for CCD, Referral Note, Progress Note and Discharge Summary - may ding for all document templates in the future)To make this clear, you need to find the actual conformance statements in C-CDA and then show how they would be tightened.YesFormatting - Testable statementsBlock Vote 4PersuasiveThis rubric is primarily focused on the relating of Goals and intervention in a Care Plan Document Type. This Rubric will be rewitten (as all rubrics will be) to be testable: Something like: If an Intervention Act (V2) [act: identifier urn:hl7ii:2.16.840.1.113883.10.20.22.4.131:2015-08-01 is present, then it must contain either an Entry Reference [act: identifier urn:oid:2.16.840.1.113883.10.20.22.4.122 2015-08-01 which points to the ID of the intervention's related goal or be contained by or contain its related Goal Observation [observation: identifier urn:oid:2.16.840.1.113883.10.20.22.4.121 using the REFR act realtionship type In document Types other than Care Plan - this will only be a warningGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
206SDNEGAll Template Ids for C-CDA and Supplemental IGs should be correct. All Template Ids should be Valid for C-CDA and Supplemental IGs. If there is a valid template ID, but doesn’t align with above then provide an Informational message saying it’s an unrecognized template ID.This is not testable. You should require a Rubric testing system to produce a list of all the C-CDA templates asserted in the document and leave it at that. you could produce a warning about unecessry (duplicated) template IDs. They do just junk up the xml.YesTemplate IDsBlock Vote 4Not persuasive with mod1.C-CDA R2.1 template IDs in CDA R2.1 files should be the expected IDs as defined in C-CDA R2.1 and C-CDA Supplemental Templates 2.C-CDA R2.1 template IDs in CDA R2.1files should contain the version extension as defined in the C-CDA R2.1 IG 3.Additional template IDs are allowed in open templatesGay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
207SDNEGThe clinicalDocument.code that specifies the document type should come from one of the concepts or value sets specified by C-CDA.If the rubric is run on a document that does not contain an assertion of being a document of one of the types defined in C-CDA, the tool produces an error saying that the document can't be validated against the rubric.YesTestable StatementsDiscuss January 2Not persuasive with modWhy is this a rubric? The document code bindings are SHALL/SHALL Example: This code SHALL contain exactly one [1..1] @code, which SHALL be selected from ValueSet ProcedureNoteDocumentTypeCodes urn:oid:2.16.840.1.113883.11.20.6.1 DYNAMIC REMOVE RUBRIC? Proposed: Remove this rubric. Add text in introductory section about schematron or other validation technology and rubric assessment: Rubrics assume that documents are schema and schematron valid. (Scorecard tool runs both schema and schematon validation rules + the rubrics. If template IDs from C-CDA R2,1 are not asserted in the document file then a tool should indicate that neither validation on base C-CDA R2.1 rules nor rubric rules can be run and therefore quality of the file can’t be determined or graded. In addition, tools should declare what document types it can evaluate, and other document type's quality cannot be assumed. Add a rubrics: Rubric: A file must pass base C-CDA R2.1 schematron without ERRORS Rubric: Assign a grade only to documents that pass base schema and C-CDA R2.1 schematron without ERRORSGay/Anne1501Lisa R. NelsonMasMDLnelson@max.md
208SDNEGInstance Identifiers should be unique for distinct acts. Encounters could have same ids when referencing the same encounter.As stated, this is not testable.YesTestable StatementsDiscuss January 2Persuasive with mod Modify Rubric to: If IDs are duplicate then the attributes of that class if present must have the same values Gay/Calvin1700Lisa R. NelsonMasMDLnelson@max.md
209SDNEGLab results should be expressed with preferred LOINC codes which are published as the top 2000 LOINC codes from Regenstrief.Rubric needs to site the exact value set to be used. YesLOINCBlock Vote 4Persuasive with mod1) We will clarify that the lab result rubric "SHOULD" is specified for the LOINC being from the top 2000 labs (b/c base standard already binds SHOULD to LOINC). 2) Howver this is not currently constructed as a value set in VSAC - but is an available download. Will provide link 2) WILL ADD: OR if a radiology result from https://loinc.org/download/loincrsna-radiology-playbook-file/ Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
210SDNEGAll problem codes should be expressed with core subset of SNOMED codesRubric needs to site the exact value set to be used. YesRWM Problem CoreDiscuss January 2Not persuasiveRemove Rubric: 1) Would need to be a change to base C-CDA standard and condier placing comment against and in that comment, consider development of a MAX value set 2) Investigate need to change/expand problem value set through discussions in forums such as C-CDA Implementation-a-thonGay/Calvin1800Lisa R. NelsonMasMDLnelson@max.md
211SDNEGThe substance administration/route code must not conceptually conflict with the narrative sigThe substance administration/route code must not conceptually conflict with the narrative or the Free Text Sig"the narrative" and "the free text sig" are conceptually two different things.YesFree text sigBlock Vote 4Persuasive with modWill ensure that medication rubrics that reference free text sig and narrative are clarified as to which is which as well as transpose them to testable statements Gay/Matt2200Lisa R. NelsonMasMDLnelson@max.md
212SD227NEGEach of the code systems, value sets specified by the CCDA IG refers back to standard terminologies like SNOMED-CT, LOINC, RxNorm, ICD9, ICD10. When codes from these code systems are used to represent structured data the short or long description assigned in the code system for the code should be used in the display name of the code element in the C-CDA documentEither remove this, or add clarification that including displayNames for the codes that are representative of the data, even if they aren't the short/long names of the code from the code system.This happens in a number of places, so this should be fixed everywhere that displayName constraints are added.YesDisplayName and Code allignmentdispo'd at WG with resolution to comment 57Not persuasiveIf DisplayName is present (and it conflicts with the codeSystem's preferred display name) then it should throw an error if it doesn't match the vocabulary (deduct points). If DisplayName isn't present then it shouldn't throw an error 2019-09-18Matt Rahn/Michael Clifton1400Michael CliftonEpicmclifton@epic.com
213SDA-TA subset of the rubric criteria are utilized A subset of the rubric criteria is utilized Copy editCopy editBlock Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Thomson KuhnAmerican College of Physicians
214SDA-Ta proposed criteria a proposed criterionCopy editCopy editBlock Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Thomson KuhnAmerican College of Physicians
215SDA-Ta significant criteria a significant criterionCopy editCopy editBlock Vote 1PersuasiveupdateMatt Rahn/Austin Kreisler2200Thomson KuhnAmerican College of Physicians
216SDA-Tthis criteria (multiple cases)this criterionCopy editCopy editBlock Vote 1PersuasiveUpdateMatt Rahn/Austin Kreisler2200Thomson KuhnAmerican College of Physicians
217SD3 ReferencesA-Chttp://wiki.hl7.org/index.php?title=CCDA_Scorecard_Rubric_UpdateThere is currently no text in this page. You can search for this page title in other pages, or search the related logs, but you do not have permission to create this page. Empty pageTechnical editBlock Vote 4PersuasiveWill put in link to current confluence siteGay/Matt2200Thomson KuhnAmerican College of Physicians
218SD3 ReferencesA-CThe C-CDA Scorecard leverages the work completed by an ONC-funded grant — SMART (Substitutable Medical Apps Reusable Technologies)404 - Page not found404 - Page not foundBlock Vote 1PersuasiveWill update to include the correct linkMatt Rahn/Austin Kreisler2200Thomson KuhnAmerican College of Physicians
219SDA-TIf there’s. (multiple cases)If there isCopy editCopy editTechnical editBlock Vote 4PersuasiveWill correct allGay/Matt2200Thomson KuhnAmerican College of Physicians
220SDNEGEffectiveDate/Time elements should have the right time and time zone offsetsMissing examplesThis text is clear to CDA experts but may not be to common developer: "+0500" or "-0500" is often mixed up. These rubrics would help developers greatly if paired with an example. (I am willing to help!) Add an example, or link to example task force example for every rubric.ExamplesBlock Vote 5Persuasive with modWe will provide a link to Example Task Force example for each rubric. If there is no example on Example Task Force, we will submit an appropriate example and work it through the Example Task Force Processes. We will identify if there are any Rubrics where an Example Task force example is not applicable and review with SDWGBrett MarquardWaveOne Associates
221A-CEach of the code systems, value sets specified by the C-CDA IG refers back to standard terminologies like SNOMED-CT, LOINC, RxNorm, ICD9, ICD10. When codes from these code systems are used to represent structured data the short or long description assigned in the code system for the code should be used in the display name of the code element in the C-CDA documentN/AConsider adding an approach to testing each row. Validators will likely have to normalize names prior to validating due to variability in sytem installsConsider adding a column for testing approachesFormattingBlock Vote 5Persuasive with modThis falls into the "Formatting" comments resolutions. This was/is the dispo: This will be addressed with the planned format changes reqested by Ben Fleissner and KP Sethi and agreed to by the WG. This reformatting was draft designed and approved at the May WG and when reconciliation is done and we are prepping to publish we will present formalized format to SDWG for approval Brett MarquardWaveOne Associates
222A-CEffectiveDate/Time elements have the right time and time zone offsets - This should be removed. This should be removed.Did you mean to include the text 'this should be removed'?Fix potential typo in problems textTech EditBlock Vote 5PersuasiveWill be removed - there were multiple comments where removal of this text was requested and removal was approved.Brett MarquardWaveOne Associates
223A-SN/AN/AConsider assigning a unique number to all rules for ease of reference.Assign a unique number for all the rules.FormattingBlock Vote 5PersuasiveThis falls into the "Formatting" comments resolutions. This was/is the dispo: This will be addressed with the planned format changes reqested by Ben Fleissner and KP Sethi and agreed to by the WG. This reformatting was draft designed and approved at the May WG and when reconciliation is done and we are prepping to publish we will present formalized format to SDWG for approval Brett MarquardWaveOne Associates
224A-S"...historical activities should be within the"N/AConsider pulling out common rules into a table and saying these apply to 'XYZ Sections"Develop common rule matrixFomattingBlock Vote 5Same as another comment (175 from KP) -- this will be done and the as above: This will be addressed with the planned format changes reqested by Ben Fleissner and KP Sethi and agreed to by the WG. This reformatting was draft designed and approved at the May WG and when reconciliation is done and we are prepping to publish we will present formalized format Persuasive with modSame as another comment (175 from KP) -- this "common rule matix/section" of the guide will be developed and This falls into the "Formatting" comments resolutions. This was/is the dispo: This will be addressed with the planned format changes reqested by Ben Fleissner and KP Sethi and agreed to by the WG. This reformatting was draft designed and approved at the May WG and when reconciliation is done and we are prepping to publish we will present formalized format to SDWG for approval Brett MarquardWaveOne Associates
225Laboratory Tests and ResultsA-QLab Result values should use preferred UCUM unitsN/ADid you ever consider contacting Regenstrief to see if there is a table mapping test results to UCUM codes so we could validate appropriate use?Improve UCUM ValidationBlock Vote 5Considered - Question AnsweredLOINC does have recommended units in the downlable spreadsheet for the top 2000 labs and - in addition recommended UCUMS (when applicable) are associated with LOINC codes in the "exUCUMunits" "exUnits" fields. Development of validation rules should be possible Add sentence to Rubric: Regenstrief provides preferred UCUM units for many LOINC codes/concepts which tools could implement to validate appropriate UCUM units per code.Brett MarquardWaveOne Associates