Yes, similarly AMT has ~8,000 - although with different granularity again.
Thanks for raising this - itâs an interesting question, but I think it risks focusing on a symptom rather than the underlying issue.
The number of Clinical Drug (CD) concepts isnât particularly meaningful in isolation. The more important question is whether CD is the right level for stable international content.
From practical experience across Australia, the UK, and Ireland - and experimenting with these alongside RxNorm - thereâs a consistent pattern:
- Alignment works well at MP and MPF
- It drops off significantly at CD
- Forcing alignment at CD introduces complexity and instability
This is largely because CD sits in the zone of real jurisdictional variation - strength representation, BoSS choices, dose form granularity, available products, local regulatory rules, and differing prescribing/reimbursement rules/frameworks. Even with perfectly aligned modelling, these wonât align cleanly across countries globally.
There may be enough consistency within parts of Europe (e.g. under EMA) for this to work more effectively, and the SNOMED International drug model clearly leans in that direction through close alignment with IDMP/EDQM. But aligning tightly to those regulatory standards makes interoperability harder for those of us working in different regulatory environments. And itâs not clear this fully resolves the problem even within Europe.
So CD doesnât consistently function as a stable shared layer in the way it is currently positioned. Even if the model were further generalised, real product variation would still limit alignment. And even with a perfectly harmonised model, the union of all CDs would include many products that donât exist in a given jurisdiction - creating additional complexity rather than value.
We already see this in Australia, where questions come up about IE CD concepts that donât map to the local reality and how to avoid them.
In that context, asking âhow many CDs should there be?â is difficult to answer meaningfully
- jurisdictions legitimately need different sets
- a global set canât be both stable and locally precise
Fortunately, interoperability approaches already account for this using decomposed data (ingredient, strength, form), and CDS/analytics largely operate at MP/MPF.
So in practice, CD becomes more about local implementation (generic prescribing) than international interoperability.
A more useful framing internationally might be
- focus on MP/MPF as the stable integration layers
- capitalise on these with concepts such as therapeutic groupers where generalisable
- accept that CD will diverge across extensions, particularly so in some areas
- simplify CD to reduce barriers and allow alignment where it naturally occurs(as Guillermo notes, solid oral dose forms tend to be easier)
At the same time, we need to be clear about what international CDs are intended for, and how they can be safely used with or without national extensions across SNOMED International members.
There are also real risks and costs here - relying on externally managed CD identifiers in core systems (e.g. prescribing or reimbursement) can create significant disruption if those concepts are remodelled, as the UK experienced. This has led some national extensions to deliberately try to insulate themselves from this international content - I believe we need to find ways to enable extension builders to do this while still interoperating with and gaining and delivering value to the international layer. If not, it is a nuisance not a benefit.
CDs are clearly important for prescribing systems, but this suggests that trying to optimise or standardise the number of CDs internationally may not be the right goal.
More useful questions might be which use cases require a genuinely globally shared CD layer?
Or viewed another way, what level of alignment is realistically achievable, and which use cases would that enable?