Section 12.140.1.1 allows the use of LOINC concepts for Procedures. I recommend we tighten up the guidance and state that LOINC SHOULD NOT be used when a more clinically specific concept code exists in one of the other allowed code systems. The existing guidance states as follows.

Only LOINC concepts that reflect actual procedures SHOULD be used

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?