To call something a "model" is to suggest that it belongs on the solution side of the fence, rather than on the side of problem description, which is where these functional specifications belong. There is nothing in these specifications which provides information about how an EHR system could be built, only information about what it might be required to do, in the specific US-case.
In fact, the main intention of this work was not as requirements for building systems – for this more technical requirements are needed, like ISO 18308. Rather it is intended as a checklist for system procurers to determine whether a given product satisfied some particular functional profile. It was designed as a way of a) comparing systems and b) determining system compliance.
We suspect, however, that the very title of the mentioned document has led to misleading assumptions. Thus the US Department of Health and Human Services (HHS) published a report on national health IT developments in 2004 containing the statement that:
- "With HHS participation, HL7 has also created a functional model and standards for electronic health records."
The Australia HealthConnect Clinical Information Project (CIP) considered the RIM in a report which came to the following conclusions :
adopting HL7 RIM as a foundation for representing all HealthConnect EHR concepts will:
- Significantly increase the complexity of concept representation;
- Entail considerable burden upon HealthConnect staff to map clinical concepts to the RIM;
- Likely lead to confusion in communication with HealthConnect stakeholders who are not well versed in HL7 concepts and methodologies.
HealthConnect (Australia). Clinical Information Project Phase 1 Report, PART A Stream 1: Clinical Information Framework. 2004.