DSI MST1.1 Comments

Definitions of Terms in Dental Metrics

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COMMENT IN ADA LETTER TO DSI 4.27.20: With regard to metrics, the ADA has always taken the position that the definition of dental metrics for both clinical quality and practice performance are professional and business matters outside the scope of standards development organizations. Standards development should not be used to usurp professional determinations regarding standards of care or clinical guidelines.

Regarding the building blocks of metrics themselves, i.e., dental clinical terminology, a viable national standard for a structured dental clinical terminology already exists, ANSI/ADA Standard No. 2000 Systematized Nomenclature of Dentistry, or SNODENT®. SNODENT is a comprehensive clinical terminology incorporating disorders, findings, observables, social factors, morphological changes, etiology, and anatomic site into a single poly-hierarchical lexicon that is fully interoperable with the medical terminology, SNOMED CT. Any attempt to define dental terminology for this space at this time would be duplicative of the ADA’s decade-long effort to develop SNODENT in partnership with SNOMED International, dental practitioners, dental specialist organizations, payers, government agencies, and system vendors.

Additional building blocks include, the International Classification of Disease, Clinical Modification, 10th Edition (ICD-10-CM) and the ADA’s Code on Dental Procedures and Nomenclature (CDT). Both are named in federal regulations authorized under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). CDT is required for reporting and documentation of dental services to third party payers, and ICD-10-CM is required for reporting and documentation of diagnoses. 

There is currently a national consortium of major dental industry stakeholders, the Dental Quality Alliance (DQA), which is very active in the domain of developing clinical quality metrics for dentistry. Its membership is broad and includes the ADA in addition to 13 other national-level dental provider associations, including public health dentists, dental specialist associations, national dental payer associations, developers, Medicaid administrators, the National Network for Oral Health Access, the Physician Consortium for Performance Improvement, and the Joint Commission. 

This national consortium has already developed dental clinical quality metrics that are already in use on a national level, and will continue doing so. Please see https://www.ada.org/en/science-research/dental-quality-alliance.

RESPONSE: DSI takes a different position on this issue that is stated in the Standard draft.

If there are any terms that are duplicative in this Standard, DSI would work in harmony with SNODENT to clarify to avoid this confusion.

Please review this Standard Draft when, please make us aware of any direct duplication of any ANSI Standard and DSI would work in harmony to clarify to avoid this confusion.