DSI CNST1.1 Comments

Visualization of the Digital Dental Patient Chart Notes (DCN)

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COMMENT IN ADA LETTER TO DSI 4.26.20: The ADA SCDI believes that standards-based electronic health record (EHR) information content and exchange methods including standards-based data extracts, standards-based messages, standards-based documents (e.g., HL7 Clinical Document Architecture (CDA) documents), standards-based healthcare transactions, and standards-based images [e.g., Digital Imaging and Communication in Medicine (DICOM) documents] should be the foundation for all EHRs. In the Health IT arena this concept is considered a best practice.

As a result, the SCDI has concentrated on the data types, formats, and structuring necessary to support timely, effective patient care. ANSI/ADA Standard No. 1084 Reference Core Data Set for Communication Among Dental and Other Health Information Systems addresses the structured data in the dental electronic health record and the HL7/ADA Dental Summary Exchange Project is creating an HL7 Consolidated Clinical Document Architecture (C-CDA) Continuity of Care Document (CCD) Implementation Guide that will offer interoperability in order to share this data across dental and medical electronic health records systems. The ADA SCDI has taken the perspective that user interface design and data visualization are best determined by vendors that create software to represent all of the data required by clinicians, who practice under laws and regulations in particular clinical settings, with particular patient cohorts. 

Therefore, this proposed standard, Visualization of the Digital Dental Patient Chart Notes, would limit vendor flexibility and innovation to address data display requirements relevant to a particular patient cohort and treatment setting. This approach would conflict with vendor electronic health record visualization efforts to meet market demand based on the requirements of practitioners in a variety of care settings. Please also note that there is no universal agreement on visualization of the data collected for paper dental chart notes due to the unique needs of various practice settings and to the differing requirements of state statutes, state board of dentistry regulation, and federal law.

RESPONSE: By definition, all Standards limit flexibility.  There is, however, a massive problem in the profession that this Standard will address and is stated in the Standard draft.  The lack of universal agreement on visualization of data in a paper chart is irrelevant to the problem that this Standard draft addresses.