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Brett reviewed the analysis table and focused in on the main conflict (red) (HL7 ObservationInterpretation codes required in FHIR Core (and used in V2 systems for 30+ years)
Discussion ensued that selection of SNOMED CT was intentional based on a USCDI commenter:
Gay's post meeting note: However, CAP's comment actually indicated that HL7 ObservationInterpretation should be the minimal standard and that SNOMED also be included as a vocabulary standard:
CAP Comment:The CAP applauds the ONC’s decision to add this data element to USCDI v4, as this data element represents the categorical assessment of a laboratory value (e.g. “high”, “low”, “critical”, etc.) and is required by CLIA. The CAP recommends that the HL7 interpretation code system and value set—which was in the original submission for this data element—be added as a minimum vocabulary standard for this data element. The CAP would also recommend that the ONC include SNOMED CT as a vocabulary standard for this element.
Gay and Brett discussed system costs and high LOE for systems to change from vendor implementations using HL7 ObservationInterpretation to SNOMED
In addition, because its an extensible binding type in FHIR Core, this means that unless the desired concept is absent in the bound value you must use that code system and not another.
Carmela asked what are the options given that ONC is unlikely to rescind the SNOMED vocabulary requirement
Brett reviewed: 3 options
Ignore the FHIR Validator.
Require every system to include both ObservationInterpretation/SNOMED (even though this breaks the extensible binding definition)
US Core uses ObservationInterpretation. ONC uses flexibility to not test for SNOMED CT.
Gay and Brett drove the point that, in this case, for the benefit of the industry (and interoperability), a USCDI errata should be issued wrt the USCDI vocabulary mandate @observationInterpretation:
From
• Systematized Nomenclature of Medicine Clinical Terms (SNOMED CT) U.S. Edition, March 2023 Release Optional: • HL7 Code System ObservationInterpretation
To:
HL7 Code System ObservationInterpretation
Optional:
Systematized Nomenclature of Medicine Clinical Terms (SNOMED CT) U.S. Edition, March 2023 Release
Carmela suggested that the ONC team sleep-on the the next steps and get back to us
Vocabulary discrepancies to continue next discussion
Gay requested that the ONC team closely review the USCDI Vocabulary Discrepancies table as they are discussing the way forward, in case there are other changes needed in the USCDI Applicable vocabulary USCDI
Brett reviewed discussions so far as present in the FACILITY INFORMATION analysis and notes document.
Looking for confirmation design of the intent of the data element. Albert W. Taylor stated this design approach look like a good start to represent the data element.
Question about location wrt Telehealth, and what would encounterLocation
Looking for confirmation that this is not a directory (service catogue) requirement FACILITY INFORMATION design notes
Received agreement from Albert W. Taylor and Carmela Minicucci Couderc that we will not be defining a catalogue or serivce directory to meet this data element, but rather will be met via encounters and /or locations within US Core profiles and C-CDA templates
Action items
Carmela Minicucci CoudercAlbert W. TaylorMatthew Rahn : ONC team sleep-on the the next steps with respect to how to handle the vocabulary conflict at Observation Interpretation and get back to us with resepect to ONC's stance and next steps