The upcoming ICD-11 will be harmonized with SNOMED CT via a common ontological layer (CO). We provide evidence for our hypothesis that this cannot be appropriately done by simple ontology alignment, due to diverging ontological commitment between the two terminology systems. Whereas the common ontology describes clinical situations, ICD-11 linearization codes are best to be interpreted as diagnostic statements. For the binding between ICD codes and classes from the ontological layer, a query-based approach is favoured.

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