Comments on the ISA are accepted year-round, and changes are made to the web version of the ISA frequently throughout the year, based on comments and other changes to the health IT standards environment as ASTP becomes aware of them. An annual Review and Comment period also occurs each summer-fall, when a majority of comments are received. See the process timeline below for more details.
Annual ISA Process Timeline
- January: Current Year Reference Edition is published, web version of ISA is available for ongoing review and comments.
- Winter/Spring/Summer: Changes may be made to the web-version of the ISA throughout the year, while the ISA Reference Edition remains static.
- Late Summer/Early Fall: Annual Review and Comment Period opens for sixty days - site changes are on hold so all reviewers are seeing the same content.
- Fall: ASTP and HHS staff review comments received, make site updates and prepare the following year's Reference Edition for publication by early January.
How to Comment on the ISA
- An ISA site account is required in order to comment on the ISA.
- If you have an account already, click the "Login" button at the top right of the ISA.
- To create an account, click the "Login" button, then "Create new account" tab above the login window. Account approval is required, and is generally completed within 1 - 24 hours.
- Once you're authenticated to the ISA site, you can submit comments on most ISA pages - just scroll to the bottom of the relevant page, enter the text of your comment (or provide attachments, if needed) and submit. Your comment will be reviewed by ASTP or other HHS subject matter experts, and changes will be considered for publication to the ISA.
- While comments by topic (posted to individual Interoperability Need pages) are preferred, and allow greater visibility to your comments by other industry stakeholders, consolidated comment letters are also accepted. You may provide these comments on general information pages, and ASTP staff will triage them, and assign them to subject matter experts.
Comment
Submitted by mbkurilo@immre… on
AIRA Comments
On behalf of the American Immunization Registry Association (AIRA) we are pleased to submit comments on the Office of the National Coordinator’s (ONC’s) updated Interoperability Standards Advisory. These comments are a compilation of the input of our members which include over 80 organizations representing Public Health Immunization Information Systems (IIS), IIS implementers and vendors, non-profit organizations and partners. Immunization Information Systems interface with a broad range of stakeholders, including providers, pharmacists, schools, child care facilities, health plans and payers, among others.
Most of AIRA's comments were uploaded on specific pages, but the comment below likely needs a new page:
AIRA proposes the addition of a new HL7-balloted Implementation guide for Immunization Decision Support Forecast (http://hl7.org/fhir/us/immds/). This emerging FHIR R4 standard has been balloted through HL7, published, and is in use in several pilots and/or proof of concepts. AIRA is happy to discuss in greater detail how to represent this new standard on the ISA. We believe this should fit nicely within Content/Structure or Services/Exchange Standards within their respective Clinical Decision Support sections.
Thank you for the opportunity to provide comments, and please let us know if there are any follow up questions.
Submitted by Bernadette Nunley on
Compassion & Choices Comment USCDIv3
Compassion & Choices provides the attached feedback on the Draft Core Data for Interoperability.
Compassion & Choices Interoperability Standards Comment-9.30.21.pdf
Submitted by Kelly Gwynn on
DirectTrust's Comments on ISA
Thank you for the opportunity to comment on the Interoperability Standards Advisory. See attached.
Submitted by bgradl@eatright.org on
Academy of Nutrition and Dietetics Comments on 2021 ISA
On behalf of the Academy of Nutrition and Dietetics, thank you for the opportunity to provide our feedback on the Interoperability Standards Advisory.
Academy Comments on 2021 Interoperability Standards Advisory.pdf
Submitted by toniki on
terminologies referenced by ISA
It would be very useful to have an "index," so to speak, of all the terminologies/code sets/vocabularies referenced by ISA and where in ISA they're referenced. Does such a thing already exist?
Submitted by College_of_Ame… on
Submitted by Emily Turek on
American Association of Colleges of Nursing submits comments
Please see attached PDF
Submitted by DrLucas on
Support of the Gravity Project’s Submission to Include SDOH
To: The Honorable Donald Rucker, M.D.
National Coordinator for Health Information Technology
U.S. Department of Health and Human Services
330 C Street SW, 7th Floor
Washington, D.C. 20201
Re: In Support of the Gravity Project’s Submission to Include Social Determinants of Health in the U.S. Core Data for Interoperability
Dear National Coordinator Rucker:
I write on behalf of the Gravity Project to ask for your quick help with a major opportunity—adding structured social determinants of health (SDOH) data to the U.S. Core Data for Interoperability (USCDI). The Gravity Project has done considerable groundwork and submitted the SDOH data elements to the Office of the National Coordinator (ONC), and ONC, in turn, has elevated the submission to the next step. The Gravity Project’s submissions would add critical domains such as food insecurity, housing instability, transportation insecurity, social isolation, and stress to the USCDI, integrated with core clinical activities such as assessments, diagnoses, interventions, and outcomes.
As a healthcare provider for many years, I have seen firsthand the impact SDOH has on managing care and improving outcomes for patients. The challenges with meeting the needs of all seeking care have been exacerbated by COVID and have highlighted the inequities in the healthcare system. Addressing SDOH will be essential to ensure adequate care is received by all by including data elements to accurately and timely identify social needs and match those needs with community resources.
The inclusion of SDOH as a new data class in USCDI, as proposed by the Gravity Project, will provide a consistent method to document and communicate these factors during a health care encounter. The Gravity Project has over 1,200 collaborators nationwide, representing diverse stakeholders who are committed to the goals of this project, standardize data collection and coding, and seamlessly exchanging SDOH data among all caregivers.
Sincerely,
Dr. Lisa Lucas
National Director Healthcare Informatics
SAS Institute
Submitted by hhaskell on
Data Element: Health Concerns
This data element may have merit, especially if there are differences in the data element for Patient Goals and Encounter Diagnosis; but may be redundant...Also, maybe difficult to capture if it is not entered in a discrete field as part of the Nursing Care Plan or Physician Treatment Plan
Submitted by hhaskell on
Data Element: Patient's Goals
Patient's goals are likely to be robustly documented in the Nurses Care Plan, depending on the type of EMR. Would want to be able to capture current and active goals and those goals that have been completed or resolved.
Help
1. Optional: Background Text / Cover Letter
The "Optional Background Text / Cover Letter" field provides space for additional context or introductory information related to your comment.
This field is entirely optional and serves the following purposes:
If you are submitting a single comment for a specific data class or element, you may leave this field blank. For multiple comments, this space is useful for explaining the overall purpose or connection between your comments.
Fig 1 The "Optional Background Text / Cover Letter" field allows users to provide contextual information or introductory remarks for their comment submission.
2. Complete the Comment Form
The comment form contains several fields that require your input:
ISA Content: This field is automatically populated based on the page you are currently viewing. No action is required.
Standards and Implementation Specifications: This drop-down menu is pre-selected based on the topic you're commenting on. The selection reflects the relevant standard or implementation specification for your current page.
Subject: Enter a concise title that summarizes the focus of your comment. This helps reviewers quickly understand the nature of your feedback.
Comment: This is the main field where you provide your detailed feedback, concerns, or suggestions. The comment box includes a text editor with formatting options that allow you to:
Use these formatting options as needed to clearly present your information.
Fig 2 The comment text editor toolbar provides formatting options including bold, italic, links, lists, tables, and image insertion capabilities.
3. Optional: Upload Supporting Files
The platform allows you to upload supporting documentation to enhance your comment:
Important: If you have already entered your comments using the form fields, there is no need to upload duplicate content in PDF format. The file upload feature is intended for supplementary materials only. Please avoid uploading files that contain the same information already provided in your comment text.
Fig 3 The "File Upload" section permits users to attach supporting documentation that supplements their written comments.
4. Optional: Save and Exit
If you need to pause your work and return to complete your comment later:
Fig 4 A red triangle with exclamation mark indicator appears next to the "Return to saved Comment" button when draft comments are saved in the system.
5. Review and Submit
Once you have completed your comment:
Fig 5 The review screen includes a "Print" button that allows users to create a record of their comment submission.