For item 5.b (CONF:1098-19207) I recommend changing the guidance for LOINC from SHOULD to MAY. If LOINC is used in the code element, or a translation child element, then it should only be an actual procedure code. The problem is that there is no LOINC Part which specifically marks a concept (term) as a procedure. Thus implementers have to rely upon the narrative description to subjectively determine whether a particular term is an actual procedure.

And there appear to be only a handful of actual LOINC procedure terms anyway, which are very general and not particularly useful. These include 29300-1 (Procedure), 29306-8 (Surgery procedure), 29554-3 (Procedure), and 58050-6 (Inpatient procedure relevant to plan of care). We have more suitable CPT and SNOMED CT concepts for those procedures. Or if there is a valid clinical use case for using those LOINC procedure concepts instead of another code system then could we at least provide some more specific guidance on that?

We have found that provider organizations are frequently using LOINC codes here which represent observations rather than procedures. I think they are trying to show that a procedure was carried out to generate a certain observation, but that seems like a misuse of this template.

Also note that in USCDI V3, the Procedures class Procedures data element doesn't have LOINC listed as one of the Applicable Vocabulary Standards. We should generally try to conform to that ONC terminology guidance unless there is a strong reason to do something different.