Feedback on the Draft Guidelines for Inpatient and Ambulatory Clinical Care Data

Andy Walsh, PhD, HMS Director of Public Health Solutions 

The inclusion of syndromic surveillance reporting in the Meaningful Use requirements has created an unprecedented opportunity for the field. By crafting guidelines for how to define that reporting, the syndromic surveillance community can have a significant impact on the way that public health agencies and healthcare providers respond to that particular Meaningful Use objective. Therefore, it is important to consider the recently released draft guidelines for inpatient and ambulatory care data and assess whether they are moving things in the right direction.

Because some eligible professionals are already working on submitting syndromic surveillance data to fulfill one of their menu options, the guidelines for ambulatory clinical care data are very much needed. However, it is important to keep in mind that it is individual professionals who need to meet Meaningful Use requirements. Therefore, an identifier for those professionals should be included as one of the required data elements for ambulatory clinical care data. This will make it possible to track which professionals are submitting the necessary data.

While eligible professionals prepare to submit this data, many public health departments are struggling to determine if they are interested in, and capable of, receiving and using ambulatory clinical care data. A strong case needs to be made for the utility of this data. The primary justification in the document is to improve the sensitivity and timeliness of syndromic surveillance relative to what can be accomplished with emergency department data. However, it is not clear to what extent these improvements are known benefits—or  hypotheses to be tested. That makes it difficult for health departments to determine if it is worth the cost to handle this data. Conversely, if this data does allow for more timely and sensitive analysis, then to what extent is there still benefit to collecting emergency department data?

An alternative way to justify collecting this data would be to expand the scope of what can be tracked via syndromic surveillance. In the ambulatory setting, it is routine to measure the patient’s height and weight and basic vital signs. These could be viewed as prediagnostic indicators of chronic conditions such as obesity and heart disease, in the way that symptoms in a chief complaint are currently used as prediagnostic indicators of the acute illnesses traditionally followed with syndromic surveillance. Collecting such data consistently and over time could be of value to various divisions of public health beyond those that currently use syndromic surveillance, broadening possibilities for acquiring funding.

Finally, the guidelines also address the collection of inpatient data. This is a natural extension of emergency department surveillance and, as such, merits consideration. From the discussion in the document, it is clear that public health views inpatient data as a separate data source. However, in the context of these guidelines, it is important to remember that ultimately inpatient data will be coming from the same hospitals that submit emergency department registrations. Will they be required to send both, and if so, in what stage? How would additional data requirements be reconciled with connections that have already be tested and attested for Stage 1?

A possible answer to these questions is that it is up to the various health departments to decide for themselves, which is true. But it would also be true if the guidelines provided clear answers to those questions. At least in that scenario, hospitals would know what the most likely answers would be, since experience with the emergency department guidelines suggests that at least some health departments will use them as the final requirements without modification. Furthermore, the other health departments who want to have different requirements would only need to communicate where their requirements differ from the base requirements, rather than all of them having to answer all open questions independently.

Making the most of the opportunities syndromic surveillance presents will depend significantly on the pace set by these guidelines. This draft represents a reasonable foundation. Making the changes recommended here – namely (1) adding an eligible professional identifier to the ambulatory clinical care data, (2) adding chronic disease prediagnostic indicators to ambulatory clinical care data, and (3) clarifying how inpatient data requirements interact with existing emergency department data requirements – would build on that foundation to take syndromic surveillance even further.

About Health Monitoring Systems, Inc.

HMS ( is a privately held company specializing in healthcare data analysis. The company processes and analyzes health‐related data in real time via a Software‐as‐a‐Service (SaaS) approach. Using this approach, HMS enables clients to increase their understanding of regional health conditions, improve quality and efficiency, and ensure regulatory compliance.

The company’s EpiCenter™ system is a first of its kind community health surveillance system for public health. HMS collects and analyzes data from more than 500 healthcare facilities across the country.

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