Planned Procedure Error

[greg....@gmail.com]

Hello,

We are receiving what seems to be an erroneous error for the b1 Ambulatory scenario 1 USCDI v3 validation. The error states "Result Description: The scenario requires Planned Procedure data but the submitted C-CDA does not contain Planned Procedure data" but as you can see in the screenshot below (and in the attached XML) we do have a planned procedure entry that (to my eye) aligns directly with the Companion Guide 4.1 specifications.

Can you confirm for us whether this is an erroneous error? If not, is there something I'm not seeing that is resulting in our entry not being identified as missing a planned procedure?

[Kim Poletti]

Hi - Thanks for reaching out. This has been logged for review and a member of the team will reach out in the near future.

[greg....@gmail.com]

Any updates on this investigation?

[Arslan Iqbal]

SITE/ETT team's internal reference SITE-4555

[greg....@gmail.com]

I created an account at the Jira site but it tells me I am unable to view the issue - it has either been deleted or I do not have permissions. Can you let me know where this one stands?

[Kim Poletti]

Hi Greg,

The ticket number is only for internal reference. The team is still investigating the issue.

Thanks,

Kim

[Ivan Quan]

Hello,

We also have this exact issue as describe by Greg. Is there an update on this?

Thanks,

Ivan

[Kyle Meadors]

The issue is that you are inserting the Planned Procedure in the Procedures component section (<templateId root = "2.16.840.1.113883.10.20.22.2.7.1"/>) but it should be in the Treatment Plan (<templateId root = "2.16.840.1.113883.10.20.22.2.10"/>) section. That is because it is "planned" as in it will happen in the patient's future so it goes into Treatment Plan. If it was a completed SDOH intervention that has already occurred, it would go in the Procedures component section but as a Procedure Activity Procedure (<templateId root = "2.16.840.1.113883.10.20.22.4.14"/>).

The Companion Guide speaks about these 2 different locations based on the timing. Also, here is an example of the coding.

https://github.com/HL7/C-CDA-Examples/blob/master/Guide%20Examples/Planned%20Procedure%20(V3)_2.16.840.1.113883.10.20.22.4.41/Social%20Determinant%20of%20Health%20Planned%20Procedure%20Example.xml 

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Kyle Meadors
@kylemeadors

[greg....@gmail.com]

Kyle,

Thank you for the information. Can you clarify where specifically in the CG 4.1 this is referenced (you mention 2 different spots). We found that the online published C-CDA 3.0 guide does reference it on the usage parameters here but could not find any such specification in the authoritative 4.1 CG.

[Kyle Meadors]

It is section 6.2.13 of the 4.1 Companion Guide - page 199 of the PDF. I've attached it here. The two spots are in that section - one addressing planned interventions and the other addressing completed interventions. 

To view this discussion visit https://groups.google.com/d/msgid/edge-test-tool/d032dec9-d936-459b-a600-d0b931c0e425n%40googlegroups.com.

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Kyle Meadors
@kylemeadors

[Greg Thole]

Thanks, Kyle. 

I see that the referenced section specifies that planned interventions must be represented with the Planned Procedure entry template (which our example aligns with) but am not seeing where it specifies that such entries cannot be populated in the Procedures section template. Apologies in advance here if I'm just completely missing it somehow.

[Kyle Meadors]

There are a few places in the main CCDA 2.1 IG spec that indicate that the right location for is Plan of Treatment. First, the Plan of Treatment section indicates that Planned Procedure can be contained in it (https://www.hl7.org/ccdasearch/templates/2.16.840.1.113883.10.20.22.2.10.html).

Conversely, the Procedure Section (https://www.hl7.org/ccdasearch/templates/2.16.840.1.113883.10.20.22.2.7.1.html) does not list Planned Procedure as an entry section is would contain (just Procedure Activity Procedure, Procedure Activity Act, Procedure Activity Observation).

As well, the section is described as containing "describes all interventional, surgical, diagnostic, or therapeutic procedures or treatments pertinent to the patient historically at the time" so that also indicates you would not expect to find future procedures in this section but only historical. The LOINC code for this Procedures Component section is officially named "History of Procedures" further showing it is in the past and not the future. 

Both of those are taken from the main CCDA 2.1 IG. The Companion Guide provides some further direction on mapping, but it is combined with the main CCDA IG for interoperability purposes of CCDA mapping. 

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Kyle Meadors
@kylemeadors

[greg....@gmail.com]

Thanks for the additional information, Kyle. That all makes sense and we've made a change to remove Planned Procedure entries from Procedures section.

However, for the Referral Note document template we were putting the Planned Procedure in the Assessment and Plan section as the R2.1 IG specifies that the document must include either (1) the Assessment and Plan section or (2) both the Assessment section and the Plan of Treatment section. We expected that this would be allowed since Assessment and Plan is effectively an equivalent of Plan of Treatment for those purposes, but that is still rendering the same error. While Plan of Treatment is specified as best practice/intended source of the Planned procedure entry, we're not seeing anything that would explicitly disallow substituting it in the Assessment and Plan section given the R2.1 IG requirements around those sections. Can a change be made to allow for Planned Procedure entries in the Assessment and Plan section, as well?

Thank you

[greg....@gmail.com]

Good morning, Kyle. Just following up on the outstanding question here to start the week. TIA!

[br...@waveoneassociates.com]

Please post an updated example, and confirm the scenario you are testing.

If you have screen shot of error, that may help SITE team. 

Best

Brett 

[Kyle Meadors]

Hey Greg. First, let me clarify that I am neither with ONC nor the SITE test tool team, so I can't speak authoritatively on this matter. I am just one of many implementers.

But I have been around a bit, currently as an EHR regulatory consultant with Chart Lux and prior to that EHR Testing Director at Drummond Group so I have been dealing with CCDAs and CCDA interoperability for 15 years now, which is why I'm active on this list and offering comments to assist but also to still learn. 

One thing with the CCDA specification is that it is very flexible, due largely to it being an "open template" design where we can add additional sections at places and also having options to place data in different locations. But that can hinder interoperability which is why the original CCDA Companion Guide came out back with the 2014 Edition FR release when it was simply "best practice" suggestions and not official compliance requirements. Since then, ONC has turned the Companion Guide into a requirement along with the main CCDA IG, and the CCDA IG vs 3.0 fully merges the core IG with the Companion Guide requirements because of how important interoperability is.

All that to say, even if you could insert the Planned Procedure in the Assessment and Plan section per the flexibility in the main CCDA IG, I can understand if it is rejected by ONC/SITE test tool because of an interoperability concern as I don't think the combined component section is the "common" method of implementation. 

But, the tool is not absolute and it can be changed, and that is why we present questions like yours here. Looking the specification, I would agree with you that Planned Procedure could be in the Assessment and Plan section (2.16.840.1.113883.10.20.22.2.9:2014-06-09), and given the HL7 authors have kept both combined or separate options available, I think the tool should accept the Planned Procedure (2.16.840.1.113883.10.20.22.4.41:2022-06-01) in either of those component sections. But the test tool team and any ONC liaisons would need to weigh in on this. They may have better reasons for not doing that. 

Finally, to Brett's recent email, and this is for everyone posting questions here, always include your CCDA that is creating the error in the email in question , if possible. Debugging or even analyzing CCDA questions is something of a dark art as much as science, and seeing the specimen at hand greatly helps make for a better response. 

Kyle

To view this discussion visit https://groups.google.com/d/msgid/edge-test-tool/862063ee-9e86-445a-afa6-3827f14098c2n%40googlegroups.com.

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Kyle Meadors
@kylemeadors

[greg....@gmail.com]

Hey Brett,

Apologies for the delay, missed this message in the thread. To clarify, the specific updated scenario we're testing is populating the Planned Procedure template in the Assessment and Plan section for SDOH Interventions when using the Referral Note doc template. Our expectation was that this would be allowed since C-CDA R2.1 IG allows for the Referral Note to use either (1) Assessment and Plan or (2) Assessment + Plan of Treatment. I've attached the example C-CDA and below is the error message of concern - indicates Planned Procedure data is not included, which we believe is because the validator is exclusively looking for it in Plan of Treatment section.

Error for Planned Procedure:

Result Description: The scenario requires Planned Procedure data but the submitted C-CDA does not contain Planned Procedure data.

[br...@waveoneassociates.com]

Please confirm the Validation Criteria and the Scenario file

I can infer based on the start of this chain, but want to make sure i am testing exactly the same way you are!

[Greg Thole]

My bad, Brett. Criterion is 170.315_b1_ToC_Amb and the scenario file is Amb sample 1 (Alice Newman).

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[br...@waveoneassociates.com]

No problem, I can recreate now, and see your error!

- Are you working through the other errors? 

- Have you considered the section.text?

The section.text currently only includes urine dipstick, and no other contained entries.

My initial reaction (which isn't always correct!) is you should be allowed to include the SDOH in the A&P section as you have suggested. Let me check with SITE team if the rigidness is for a reason I am not recalling.

Best

Brett  

[Greg Thole]

Thanks, Brett!

We are working through the other errors. The vast majority are related to provenance (time stamps and author names) that we will be requesting test data change approvals on with our ATL and we have code changes in progress that we expect to remedy the remainder. We also have updates in progress for the narrative text, just isn't reflected in this example. Full disclosure - we just manually manipulated that sample to move the Planned Procedure entry into A&P and test how the validator responded before finalizing designs for code changes. 

Anyway, glad to hear your initial reaction aligns with our thinking. Look forward to hearing what the SITE team has to say.

Thanks again!

To view this discussion visit https://groups.google.com/d/msgid/edge-test-tool/1effeb5b-6021-4674-8089-b35df5096cedn%40googlegroups.com.

[Dan Brown SITE]

Hi Greg,

We have analyzed and we agree with Brett. You should be allowed to include the SDOH in the A&P section. We will look to update the content validator as such so that it is not so strict. Unfortunately, we can't give you a specific timeline for the update as there are many competing priorities.

[greg....@gmail.com]

Thanks for confirming, Dan. We will keep an eye out for the update. Out of curiosity, is there a planned upcoming release with other changes/corrections that we can expect?

[Dan Brown SITE]

We typically release on the last Monday of each month. It's certainly possible that the fix will be included then. It's also possible we will do an additional release in between this month. It is less likely a fix for this will be included if that happens, though.

[James Spillman]

A fix for this has been deployed. Can you retest?

[greg....@gmail.com]

Apologies for the delay as I'm just returning from parental leave today. I checked with my colleagues and they did successfully test the deployed update. Thank you very much for the engagement on this item!