June 25, 2003
The Honorable Tommy Thompson
Secretary
Department of Health and Human Services
200 Independence Avenue SW
Washington, D.C. 20201
Dear Secretary Thompson:
The National Committee on Vital and Health Statistics (NCVHS) commends you
for your commitment to move toward uniform government adoption of clinical data
standards that you announced on March 21, 2003. NCVHS recognizes and
appreciates that there is new momentum to adopt clinical data standards that is
driven by you and the Consolidated Healthcare Informatics Initiative (CHI).
Consequently, NCVHS is now working closely with CHI to study, select and
recommend patient medical record information (PMRI) standards. Given your
strong interest in adopting PMRI standards, we thought you should be aware of
the progress that NCVHS is making in this area and of some observations that
are likely to influence our next set of NCVHS clinical data standards
recommendations.
NCVHS began the process of studying, selecting, and recommending patient
medical record information standards under the directive of the Health
Insurance Portability and Accountability Act of 1996. Accordingly, the
Committee completed the NCVHS Report on PMRI Standards in August 2000. This
report set forth a framework and guiding principles for the selection of these
standards. NCVHS then employed these guiding principles to select and recommend
PMRI Message Format Standards to you. The Department adopted them as part of
the first set of clinical data standards in your announcement of March 21,
2003. At the current time, NCVHS is evaluating PMRI terminologies, which we
plan to recommend as clinical data standards for your adoption.
Here is a brief review of the status and direction of NCVHS activities that
will lead to recommendations for PMRI terminology standards:
- In August 2002, NCVHS convened 1-1/2 days of hearings to solicit guidance
from healthcare industry experts regarding the need, the scope, the priorities,
and the criteria for selection of PMRI terminology standards. Testifiers
recommended that the committee focus on identifying those PMRI terminologies
that can serve as a stable and consistent core and then identify
domain-specific terminologies that can be referenced or mapped to the core.
- NCVHS then prepared a comprehensive questionnaire to solicit information
from all terminology developers that wished to have their terminologies
considered for selection as PMRI terminologies. This questionnaire reflected
the guidance we received from the testimony in August and NCVHS criteria for
selection of PMRI terminologies. We received more than forty responses to this
comprehensive questionnaire. The responses were analyzed to determine which
terminologies were technically qualified to be recognized as part of the core
PMRI terminologies. This initial set of candidate terminologies was included in
a preliminary report that was reviewed by NCVHS on March 25-26, 2003.
- NCVHS solicited additional information from terminology developers and
then updated the preliminary analysis, generating a revised list of candidates
in a second draft report that was distributed to the Standards and Security
Subcommittee on April 17, 2003. The revised list identifies 12 terminologies
that meet NCVHS technical criteria for selection as a core PMRI terminology
standard.
- NCVHS distributed this second draft analysis on May 2, 2003, to all
terminology developers to solicit a final set of reviews, comments, and
corrections.
- NCVHS invited users of the 12 terminologies that meet the technical
criteria to serve as core PMRI terminologies to testify to NCVHS on May 21-22,
2003. In total, twenty-four users, including representatives from healthcare
provider organizations, healthcare information system vendors, and developers
of related terminology services testified to NCVHS.
Although it is premature at this time for NCVHS to recommend which
terminologies should be selected as the initial set of core PMRI terminologies,
which terminologies should be recognized as valuable domain-specific
terminologies, and in which context they should or should not be used, it might
be valuable for us to share with you the following observations that are likely
to influence our recommendations.
- In the August 2002 and May 2003 NCVHS hearings, testifiers expressed
overwhelming support for the government to take leadership by identifying a
core set of non-redundant clinical terminologies for healthcare.
- In the May 2003 NCVHS hearings, terminology user testifiers expressed
broad support for the adoption of SNOMED-CT and the laboratory portions of
LOINC as part of an initial set of core PMRI terminologies. The support for
SNOMED CT was dependant on clarification of licensure costs.
- Testifiers also indicated that NCVHS should recommend an appropriate set
of drug and medical device terminologies as part of the core set of PMRI
terminologies. However, there was not a consensus as to which drug or device
terminologies should be selected. NCVHS intends to explore further these two
areas in hearings planned for August.
- After the initial set of core PMRI terminologies is selected the issues of
content overlap, interfacing, integrating, and mapping, as well as maintenance
and distribution, will be investigated and addressed in the September
recommendations and/or subsequent reports.
NCVHS plans to present its final recommendations for the set of core PMRI
terminologies to you at the end of September 2003. In the meantime, we hope the
information in this progress letter will be of value to you for anticipating
next steps toward building this central component of the National Health
Information Infrastructure.
Sincerely,
/s/
John R. Lumpkin, M.D., M.P.H.
Chair, National Committee on Vital and Health Statistics
Cc: HHS Data Council Co-Chair