Co-author: Kanwarpreet Sethi

Lantana Consulting Group commented on the testimony provided on February 16, 2016, to the National Committee on Vital and Health Statistics (NCVHS) Subcommittee on Standards, Hearing on HIPAA and ACA Administrative Simplification — Phase IV Operating Rules and Attachment Standard (Part 2).

We agree with the many comments urging a low bar for initial compliance, to be raised over time in accordance with industry readiness. Our response focused on how to simplify the program and raised a risk that the sub-committee may not have considered.

Our key recommendations include:

1. Semi-Structured Notes: The semi-structured option would include an XML note that may or may not contain semantic coding. This intermediate-level report provides a significant advantage over the unstructured report, and yet it’s easier to achieve than structured reports.
2. Guidance on Clinical Document Type Codes: 
   1. C-CDA Documents: Drop the mention of the RELMA HIPAA document types and rely on the VSAC value sets, as referenced in C-CDA.
   2. Non-C-CDA Documents: Reference the LOINC Ontology in preference to RELMA.
3. Non-Clinical Document Types: The LOINC Ontology contains high-level codes for non-clinical (administrative) document types. Stakeholders should consider the level of specificity needed and fill out the code set appropriately.
4. Disallow the CDP1 Option: The level of semantic coding that would make CDP1 valuable is far distant as a national capability. Based on its templates, CDP1 would precipitate changes/redundancies in clinical workflow.
5. Publication Format: An electronic form of the standard should be developed with tailored views of just the requirements needed for unstructured (or semi-structured) documents.

At Risk: While portions of the C-CDA have had private and public sponsorship over the years, today it relies on volunteer coordination provided under the auspices of the HL7 Structured Documents Work Group (SDWG). The consolidated body of work in C-CDA is over 1,000 pages (in print). Stakeholders should consider a model similar to that adopted for FHIR. See Consolidated CDA: Pursuing Continuous Improvement

At Lantana, we built our expertise through more than a decade of involvement in standards development and deployment. We appreciate the opportunity to respond to the testimony presented to the NCVHS sub-committee.

For the full draft of our comments, click here.