Dear all, 

I would like to ask you for your opinion on a statement in ISO/DTR 20514 
(Definition, scope and context of the EHR), which says that "[...] a 
standardised EHR reference model is required for achieving functional 
interoperability [...]" (page 7 of ISO 20514).

Functional interoperability is defined as "the ability of two or more systems 
to exchange information (so that it is human readable by the receiver)".

I am now wondering why an EHR reference model is seen to be REQUIRED for 
achieving functional interoperability. If I exchange bare PDF-documents 
(without any describing metadata) between two EHR systems, then I would say 
there is a good chance that these docs are readable by a human receiver and 
thus functional interoperability should be achieved although clearly an EHR 
reference model is not used.

I agree that an EHR reference model alone is not enough to achieve semantic 
interoperability (agreed archetypes and terminology are missing) and therefore 
by using an EHR reference model alone one can still only achieve functional 
interoperability. However, this seems to me as some kind of "advanced 
functional interoperability", where the receiving EHR system knows the basic 
components (the RM classes and their attributes) from which EHR information is 
composed.

So I have the impression that an EHR reference model helps to achieve some kind 
of "advanced functional interoperability", but I would not say that it is 
REQUIRED to achieve functional interoperability (refering to the PDF-exchange 
as a counter-example).

What do you think?

Thank you for any comments and best regards,
Georg 
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