DSI GSST1.1 Comments

Graphic Symbols – Pictograms Representing Information Regarding the Healthcare Patient

COMMENT IN ADA LETTER TO DSI 4.26.20: The DSI proposed standard would limit vendor flexibility and innovation to address data display requirements relevant to a particular patient cohort and treatment setting. The ADA SCDI has taken the perspective that user interface design and data visualization, including graphic symbols and pictograms, 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. 

This approach to prescribing visualization, including graphic symbols and pictograms, could inhibit vendor ability to meet market demand based on the requirements of practitioners treating differing patient cohorts 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. 

As discussed with BSR/DSI CNST1.1-202x (Number 1 above), the ADA 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. The joint ADA-HL7 Dental Summary Exchange Project is creating an HL7 Consolidated Clinical Document Architecture (C-CDA) Continuity of Care Document (CCD) Implementation Guide that will enable sharing of this data across dental and medical electronic health records systems. 

RESPONSE: DSI has a different perspective on this issue that is stated in the Standard draft. While all Standards limit flexibility in some way, DSI believes that there is no limits when it comes to innovation.