DSI RST1.1 Comments

Documentation of the Written and Electronic External Referral of the Dental Patient

COMMENT IN ADA LETTER TO DSI 4.26.20: As noted above, the ADA SCDI has been working on this use case for exchange of data. ANSI/ADA Standard Nos. 1079 and 1084 are the basis for this work and define necessary data to support referrals, consults, and continuity of care. 

The ADA is collaborating with HL7 and the Federal Health Sector, including the Department of Defense, on dental projects in HL7. These include standards for electronic claims attachments to payers as well as the exchange of dental data for referrals with both medical and dental providers using clinical document architecture (CDA) and the Fast Healthcare Interoperability Resources (FHIR) formats. These joint ADA-HL7 projects are all based on the core data content defined in ADA SCDI standards. The ADA-HL7 joint effort also includes an EHR Dental Functional Profile that is consistent with HL7’s medical functional model. This new Dental Functional Profile references HL7 and ADA data standards as part of the functional profile requirements.

This DSI proposal would not only duplicate the ADA dental data content work, but also parts of certain HL7 standards, namely:

  • ANSI/HL7 CDA, R2.1-2019, HL7 Clinical Document Architecture, Release 2.1
  • ANSI/HL7 FHIR R4.0, Fast Health Interoperability Resources (FHIR) Release 4.0
  • ANSI/HL7 EHR-S Functional Model, Release 2.1

It may also duplicate parts of the following International Standards Organizations work products:

  • ISO/IEC 40240:2011, Information technology — W3C Web Services Addressing 1.0 — Core 
  • ISO 12052:2017, Health informatics — Digital imaging and communication in medicine (DICOM) including workflow and data management

Should this proposed DSI work item proceed to completion, it is unlikely to be implemented, or, if it is, the implementers risk siloing themselves away from the rest of the health care industry for the following reasons:

  1. The US Department of Health and Human Services is moving forward with regulations to promote interoperability and prevent information blocking practices by developers, providers, and payers.
  2. These rules are coming from the Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare and Medicaid Services (CMS).
  3. The ONC regulation includes EHR certification criteria that require developers to support HL7 CDA R2.1 and FHIR 4.0 and further defines information blocking.
  4. The CMS regulation requires payers and providers alike to be able to exchange patient information via FHIR-enabled Application Program Interfaces (APIs).

In order to meet these proposed criteria, implementers will probably need to pay for additional development, or risk complaints of information blocking, meritorious or otherwise.

RESPONSE: DSI was informed by an ADA SCDI member of the late 2019 passing of ANSI/ADA Standard 1084 after the submission of this PINS. DSI agrees that this PINS is duplicative of this ANSI/ADA Standard 1084, so DSI will be abandoning pursuing this Standard. 

It bears mentioning, however, that this is the only one of these seven Standards that the founder of DSI discussed with members of the ADA SCDI prior to leading the formation of DSI and the only one that is duplicative in nature.