Comment:

• Consider a history section: e.g. symptoms, hormones, family history

• Observations should include clinical signs: e.g. scar, implant, birthmark, etc… these are not in the definitions

• Does the model consider double-reading?

• Consider structure for screening vs diagnostic reporting

• Consider a section for intervention (e.g. biopsy)

• Consider scope of dose reporting, FHIR does not currently provide a resource for this.

• Modeling approach

o ACR BI-RADS should be referenced (all or relevant sections)

o There does not appear to be consideration of DICOM Breast Imaging Report Templates (a solid model that has been in place for nearly 15 years)