eCR/RCKMS Community of Practice

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representedCustodianOrganization and id extension

Does anyone know the requirements for the id extension in represented custodian org section?  does it have to be an NPI?  I can copy below from the latest IG.  I have a site that is using an OID and not sure if I can give feedback that it is a less than helpful number to have.
Thanks

From IG: The custodian element represents the organization that is in charge of maintaining and is entrusted with the care of the document. There is only one custodian per CDA document. Allowing that a CDA document may not represent the original form of the authenticated document, the custodian represents the steward of the original source document. The custodian may be the document originator, a health information exchange, or other responsible party.
17. SHALL contain exactly one [1..1] custodian (CONF:1198-5519).
a. This custodian SHALL contain exactly one [1..1] assignedCustodian (CONF:1198-5520).
i. This assignedCustodian SHALL contain exactly one [1..1] representedCustodianOrganization (CONF:1198-5521).
1. This representedCustodianOrganization SHALL contain at least one [1..*] id (CONF:1198-5522).
a. Such ids SHOULD contain zero or one [0..1] @root="2.16.840.1.113883.4.6" National Provider Identifier (CONF:1198-16822).

What I received from an organization: 
<representedCustodianOrganization>
<id extension="urn:oid:2.16.840.1.113883.3.787.6.1" root="2.16.840.1.113883"/>

What I am used to seeing:
<representedCustodianOrganization>
          <id extension="1265629133" root="1.2.840.114350.1.13.2.2.7.5.737384.399"></id>
          <name>AURORA HEALTH CARE</name>

Comments & Events

Aaron Ling
My understanding of the IG is that it the represented custodian org id is recommended (SHOULD) to be an NPI, but it's not a requirement.

I think it's fair to tell the site the OID is not useful and you'd prefer an NPI. I believe that would fall under PHA validation jurisdiction.
Kristi Eckerson, RCKMS Administrator at HLN Consulting
I agree fully with Aaron's comments, though I do want to add some to his second statement.
The ID root included in the sample is for HL7 as an organization. The extension (which improperly includes the root value ) identifies a Mayo Clinic site at 800 Washington Ave. North Suite 400. Minneapolis, MN 55401. As provided, the "extension" could have been properly identified as the "value" of the ID, or should have only included the extending segments of the full OID.

IDs (like codes) are only meaningful when expressed "in context". 123456789 may be my driver's licence number, or my SSN, or my student ID, or.... In both cases (ID or code-value) meaning can only be ascertained within the context of the authority assigning the value. Think about the code "M" - Does it mean "meters", "miles", "months", "minutes", "Male" or the month of "May"? It is only in context that meaning can be known.
Deb Loniewski
Hi all,
In Michigan we receive the representedCustodianOrganization (RCO) with primarily, both the ID extension and the root OID, which is what we want. The RCO OID represents the Parent Organization which may have multiple Hospitals with unique IDs, but the OID remains the same. We also see that Epic sites do not always use the NPI for the RCO ID extension. This is not a problem as long as the RCO ID is consistent for the individual Hospital within that Organization.
We are having problems with a small number of out of State Hospital Systems with some physician practice instances within Michigan that do not send us an RCO OID. One of these sites is Parkview Health from Indiana.
The data may not be helpful to one state but essential for another. Wish the messages were more consistent but we see a lot of variability. 
Curious how other States capture the "Care Service" location? Please share...

Thanks in Advance!
Deb
Karla Norsworthy
Deb,
In NC we currently rely on the representedCustodianOrganization (along with the identified diseases in the associated RR)  to determine when to route an ECR to test or production.   We have had to reach out to a few organizations that leave the root of the  OID empty. So far, we've been successful in getting the organizations to change and provide the data.  
We are being encouraged to move from this approach to use of the S3 metadata.   (For some reason the specification marks the OID root as a "should" rather than a "shall".) I would really like to see the facilities use this field consistently.  I worry about the reliance on facility names in the S3 data - as we see these facilities bought and sold and renamed at a rapid rate.
Karla
Deb Loniewski
Hi Karla!
I appreciate your sharing NC's process. Unfortunately, we cannot use the meta-data because we do not receive it. We use our State HIE and therefore the meta-data is stripped off prior to hitting our interface engine. This requires us to use what is sent in the message.

We will ask HCOs to send the root OIDs. Hopefully we'll be successful too!
Best, Deb
Karla Norsworthy
Thanks Deb - I would really rather continue to use data inside the eCR as well.  I'm not sure if we can build some momentum to make the full represented Custodian Organization (ID and root) required.
Karla