Submitted by SuzyRoy on
Recommendation for required terminology standard designation
SNOMED International commends ONC for naming SNOMED CT as an applicable vocabulary standard for Referral Orders but we recommend that this be elevated to a required designation. SNOMED CT procedure hierarchy provides a comprehensive, nationally and internationally standardised vocabulary for referral and consultation coding including 307837007 |Referral to person (procedure)| and 306206005 |Referral to service (procedure)| and its descendants which enables consistent, computable referral documentation across care settings. NCQA's HEDIS quality measures already incorporate SNOMED CT-coded referral value sets, demonstrating validated real-world adoption at scale.
Reliance on local or proprietary referral codes which still remain prevalent in EHR implementations, creates barriers to the care coordination interoperability goals of the 21st Century Cures Act and ONC's TEFCA framework. SNOMED CT designation as a required standard for Referral Orders, consistent with its use in CMS Quality Payment Program (QPP) technical specifications, would drive convergence across implementations and eliminate the need for costly mapping between systems.
Submitted by portmi3 on
Commenter: Michael Porter, Mport Media Group, Inc. (Discharge Bridge — care-transition orchestration).
We support USCDI v7 Referral Order, Referral Note, and Reason for Referral for hospital → SNF / post-acute exchange. Please keep SNF / post-acute explicitly in examples and vocabulary guidance.
We support Medication Order and Medication Administration for transition medication safety, and recommend leveling Level 0 Discharge medications (and Medication List Type as applicable) so implementers can exchange a reconciled active list at handoff distinct from open orders vs administration.
We support Encounter Disposition, Appointment, Healthcare Agent, and Discharge Summary Note for operational handoff / decision-maker / disposition context, mapping to these existing elements before inventing new definitions.
We recommend evaluating structured Prior Authorization Determination Status for inclusion or leveling (ONDEC or comment adjacent to Health Insurance Information / related coverage elements), because authorization fragmentation blocks timely acute→post-acute transitions and is relevant under CMS interoperability and prior-authorization directions that reference USCDI. Prefer placement under Health Insurance Information or Orders as ONC prefers — not a new data class.
Prefer mapping operational handoff needs to existing USCDI elements — Encounter Disposition, Discharge Summary Note, Healthcare Agent, Facility Information — and leveling Level 0 Discharge medications — before inventing new definitions.
This comment reflects an implementer perspective. It does not imply ONC endorsement and does not claim HIPAA or SOC 2 certification.