HL7 SDWG Topic
October 29, 2015
David Tao
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HL7 Success! C-CDA 2.1 is cited, and Care
Plan is in 2015 Edition Certification Final Rule
Common Clinical Data Set (CCDS) has been
expanded with specific C-CDA sections
related to Care Plan
CCDS is required in Transition of Care (ToC)
exchanges
The net effect looks like a conflation of ToC
documents and parts of Care Plan
◦ Will this be what clinicians want?
◦ Will developers know what they should do?
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ToC objective in MU2 is being met by
summary documents such as CCD,
Consultation Note, Discharge Summary…
ToC document in 2015 edition is not
significantly different, except for expanded
CCDS. Most vendors will probably want to
continue producing the same doc types
Care Plan document is brand new in 2015
edition, and follows C-CDA as intended
A couple of commenters expressed concern regarding
whether this proposal aligned with the C-CDA
standard… A few commenters noted that we should
clarify the intent of the “Goals Section” and “Health
Concerns Section.” These commenters noted that the
“Goals Section” and “Health Concerns Section” of the CCDA Care Plan document template provide more
structure and were originally designed to be used with
the Care Plan document template. However, other CCDA document templates, like CCD, allow for health
concerns and goals to be included as a narrative within
the “Assessment Section (V2),” “Plan of Treatment
Section (V2),” or “Assessment and Plan Section (V2).”
We have reviewed the CCDA 2.1 standard and believe
there is no misalignment…Therefore we have adopted
the specific data elements as proposed (i.e.,
“Assessment Section (v2)” and “Plan of Treatment
Section (v2)” or “Assessment and Plan Section (v2);”
Goals Section;” and “Health Concerns Section”). We
clarify that we will certify Health IT Modules to the
“Goals Section” and the “Health Concerns Section” from
the Care Plan document template for the purposes of
meeting the Common Clinical Data Set definition. Thus,
other C-CDA document templates such as CCD, Referral
Note, and Discharge Summary would need to be able to
exchange the structured “Goals Section” and “Health
Concerns Section” in order to meet the “Common
Clinical Data Set definition.”
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Care Plan document SHALL contain Health Concerns and Goals
sections
CP SHOULD contain Interventions and Health Status Evaluation &
Outcomes sections (note: Cert Rule requires these in Care Plan doc)
ALL of these sections are only specified in a Care Plan document
Care Plan SHALL NOT contain a Plan of Treatment Section (V2)
(CONF:1198-31044)
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PoT (known as “Plan of Care” section in CCDA 1.1) was
renamed in CCDA 2.x.
PoT is required in Discharge Summary, optional in other
document types, but prohibited in Care Plan
PoT section includes narrative and may include structured
entries such as “planned x” where x can be act, encounter,
immunization, medication, observation, procedure, or
supply. May also include Goal observation, handoff
communication participants, instruction, nutrition.
Most EHRs probably don’t create structured PoT section; if
structured, there was little or no guidance. Care Plan
document attempted to provide a better structure
“Assessment” + “PoT” sections are logically equivalent to
the single “Assessment and Plan Section”
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First Impression: the Rule introduces issues
◦ Internal Redundancy because Assessment and PoT
section(s), Health Concerns and Goals sections must now
be in the same document
◦ Overlap between ToC and Care Plan certification criteria
◦ Increased size of ToC document
◦ Potential Confusion:
 Developer: which data goes in which sections and entries?
 Provider: where do I find the Plan? Is it in one place or
several?
◦ Care Plan document is co-opted by ToC document. If
produced, much of it is redundant with ToC doc.
(Note: Care Plan is a certification requirement, but not a
MU3 requirement)
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Is this a major problem, or not a problem, or
something in between that can be clarified by
guidance?
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Clarify how to implement ToC such that it is relevant and
pertinent to clinicians, right-sized, easily readable,
internally consistent, non-redundant, not “choppy”
Clarify Range of Care Plan Info: longitudinal patientcentered vs provider/encounter-specific? If both, what
goes where?
Expand Care Plan diagram, showing relationships among
sections and entries beyond the original CP document
(Lisa’s PACP diagrams are an example). For example,
should PoT Section be a shell that points to other sections?
Dual-compliant ToC/CP document that adds remaining
Care Plan sections (Interventions, Health Status
Evaluation). At least that would be holistic, rather than
having “half a Care Plan”
Ideas?