The answer is “yes”. Details below…

Allergy and Problem Concern Acts
The article Concern acts in C-CDA, overviews the special use of an act clinical statement XML entry to “wrap” the observation clinical act statements used in Problem Section and Allergy Section templates in C-CDA documents.

As explained in the article, the purpose of these “concern act” templates is to enable a set of related observations (and possibly other clinical statements) to be viewed together as supporting an overall concern about a given problem or allergy.

Usually There Are Single, Independent Observations
As a practical matter, however, most problems and allergies represented in C-CDA documents do not use this “grouping” capability of the Allergy Problem Act or Problem Concern Act templates. Most problems or allergies reported in C-CDA documents are stand-alone observations about the presence or absence of a given allergy or problem.

There is a relatively complex XML syntax necessitated by the “concern act”, in order to represent a single problem or allergy observation. This syntax is outlined below (this example is taken from the Problems Section):

<section>
   ...
   <entry ...>
      <act ...> <!-- Problem Concern Act -->
         ...
         <entryRelationship ...>
            <observation...> <!-- Problem Observation -->
            </observation>
         </entryRelationship>
         ...
      </act>
   </entry>
</section>

A Problems Section with a list of problems where each problem is represented by a single, independent observation, nonetheless requires that the act and entryRelationship elements (and their associated sub-elements and attributes) need to wrapped around each observation in the list, as follows:

<section>
   ...
   <entry ...>
      <act ...> <!-- Problem Concern Act #1 -->
         ...
         <entryRelationship ...>
            <observation...> <!-- Problem Observation #1 -->
            </observation>
         </entryRelationship>
         ...
      </act>
      <act ...> <!-- Problem Concern Act #2 -->
         ...
         <entryRelationship ...>
            <observation...> <!-- Problem Observation #2 -->
            </observation>
         </entryRelationship>
         ...
      </act>
   </entry>
</section>

Concern Act is Always Required
This “wrapping” of each individual problem or allergy observation in “concern act” adds XML syntax overhead and there is some question about the value it provides.

There is some ongoing debate/discussion on this issue in the relevant HL7 working groups. Future versions of the standard may change this approach, but currently, this is the way it works.

Refer to the article Interpreting C-CDA R1.1 concern acts, for a discussion of how to properly use and interpret the relatively limited capabilities of the two concern act templates (Allergy Problem Act and Problem Concern Act) in C-CDA R1.1.

Other CDA PRO Know Articles Referenced In This Article