Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.

Data Element

Mental/Cognitive Status

Assessment of a patient's level of cognitive functioning. (e.g., alertness, orientation, comprehension, concentration, and immediate memory for simple commands)

Applicable Vocabulary Standard(s)

Applicable Standards
  • Logical Observation Identifiers Names and Codes (LOINC®) version 2.72


Depression Assessment

Health Status Assessments: Mental/Cognitive Status


HL7 recommends that Depression Assessment listed under Health Status Assessment as an example screening of interest, recognizing that not all health information technology (HIT) may need to support that when being certified.  Depressive disorders are common mental disorders that occur in people of all ages. Major depressive disorder (MDD) is the second leading cause of disability worldwide, affecting an estimated 120 million people. Depression has a large effect on health care costs and on productivity.  Adolescents with depression have higher medical expenditures, including those related to general and mental health care, than adolescents without depression. For working-adults, one study showed a relationship between the severity of depression symptoms and work function and found that for every 1-point increase in a Patient Health Questionnaire 9 (PHQ-9) score (a measure of depression severity); patients experienced an additional mean productivity loss of 1.65%. Even minor levels of depression symptoms were associated with decreases in work function. The U.S. Preventive Services Task Force (USPSTF) recommends screening for depression among adolescents 12-18 years and the general adult population, including pregnant and postpartum women. 

Comments on Mental Function / Mental Health Status and Cognitive

Health Status – Mental Function / Mental Health Status and Cognitive Status


NACHC supports the separation of the current "Mental/Cognitive Status" element into two distinct components: "Mental Health Status" and "Cognitive Status". While these elements naturally fall under the broader category of "Health Status Assessment", it is crucial to recognize their unique clinical nature and definitions. "Cognitive Status" is assessed using established measures like MoCA, SLUMS, or MMSE, evaluating orientation, attention, memory, judgment, and reasoning. In contrast, "Mental Health Status" encompasses diagnoses such as depression, anxiety, and ADHD, and is evaluated using validated assessments like PHQ-9, GAD-7, and the Vanderbilt Assessment Scale. NACHC encourages ONC to support work on a list of preferred instruments and mappings that will assist organizations in normalizing these types of data.


The urgency of this matter is underscored by staggering statistics from the Centers for Disease Control and Prevention (CDC). Over 50% of individuals in the United States will receive a mental health diagnosis in their lifetime, with more than 57 million annual visits to physician offices where mental disorders are the primary diagnosis. Additionally, the U.S. Preventive Services Task Force (USPSTF) has recommended depression screening for various populations since 2016, extending to adolescents, children, and pregnant or postpartum women as of 2022.


Furthermore, the National Committee for Quality Assurance (NCQA) places a high priority on the diagnosis of depression due to its well-documented impact on physical health, mental health, and functional status. This commitment led to the development of five depression care measures within the Healthcare Effectiveness Data and Information Set (HEDIS), notably focusing on the PHQ-9 assessment tool.


We believe that implementing these recommendations will significantly enhance the comprehensive assessment of mental health, leading to more effective care and improved patient outcomes.

PACIO Project Recommends Change to Disability Status

  • Data Class: Health Status Assessments (Draft V4) 

  • Data Elements: Functional Status, Mental/Cognitive Status, Disability Status (Draft V4)  

  • Recommendation: Remove the Disability Status data element from the Health Status data class and instead add a new data element entitled, “Disability” to the patient demographic data class.  

  • Rationale: The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, with the goal of establishing a framework for the development of FHIR implementation guides to facilitate health information exchange. The PACIO Community supports CMS and CDC submission, which reflect their view that identifying a person with a disability does not necessarily have any bearing on how healthy a person is or the status of one’s health. However, collecting and transmitting data on disability in a standardized way alongside other demographic factors is vital to recognition of disability as a key component of identity and allows analysis of outcomes and conditions in an intersectional way, incorporating race/ethnicity, age, sex, and disability together for a more comprehensive understanding of patient demographics. 

PACIO Project Recommends Value Set Adoption

  • Data Class: Health Status Assessments (Draft V4) 

  • Data Elements: Functional Status, Mental/Cognitive Status, Disability Status (Draft V4) 

  • Recommendation: Adopt the value sets developed for the “Personal Functioning and Engagement” IG as part of the USCDI V3 updates to the U.S. Core IG to incorporate Functional Status and Cognitive Status data elements. 

  • Rationale: The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, with the goal of establishing a framework for the development of FHIR implementation guides to facilitate health information exchange. Functional and Mental/Cognitive Status are important data classes that have widespread use in all healthcare settings and sharing the content of standardized PAC assessments (some of which are federally required) with non-PAC providers (e.g., hospitals, physicians) would improve the quality of care and facilitate care coordination during transitions of care. These instruments use a consistent framework mapped to HIT standards for functional status, contain administrative and clinical patient data, can be considered as individual data elements (mobility, pressure ulcer, transportation, social isolation, etc.) or a “questionnaire” of grouped data elements together (MDS, OASIS, IRFPAI, FASI etc.) The PACIO Community wishes to update the ONC/USCDI with current efforts relating to several of the data elements under the proposed USCDI V4 data class of Health Status (Health Concerns, Functional Status, Disability Status, and Mental/Cognitive Status). The PACIO Community recognized the value of creating data models (like Gravity’s SDOH) that allow for expansion across multiple domains. As a result, PACIO created a new FHIR Implementation Guide (IG), “Personal Functioning and Engagement,” which consolidates PACIO’s prior published IGs (STU1) “Cognitive Status” and “Functional Status”. The PACIO group also is incorporating data elements of communication, swallowing, and hearing to the “Personal Functioning and Engagement” IG currently under development. Currently, the Personal Functioning and Engagement IG data structures focus on observation/ assessment data. However, the IG could include future expansion using additional resources as the work matures. The concept of “Personal Functioning and Engagement” encompasses both an individual’s abilities (positive strengths) and disabilities (impairments) across all types of functioning. The PACIO Community examined and incorporated the International Classification of Functioning, Disability and Health (ICF) as a conceptual framework that underpins this new PACIO Personal Functioning and Engagement IG. PACIO’s current work focuses on ICF “Body Functions” including mental functions, sensory functions (including hearing), voice and speech functions, and ingestion functions (swallowing). Current PACIO focus for ICF “Activities and Participation” functions include Learning and Applying Knowledge, Communication, Mobility, and Self-care.  

PACIO Comments on Mental/Cognitive Status

  • In the USCDI v.3, the definition of Cognitive Status does not mention worsening/better whereas the functioning definition does. The current definition of Functional Status (“Assessment of a patient’s capabilities, or their risks of development or worsening of a condition or problem. (e.g., fall risk, pressure ulcer risk, alcohol use)" is includes the capabilities (positive aspect of functioning) and the risk for worsening (negative aspect of functioning). This may be confusing to the user.
    • The PACIO Community recommends the adoption of the International Classification of Functioning, Disability, and Health (ICF) conceptualization of functioning. The ICF defines functioning as the positive or neutral aspects of the interrelationships of the person, their health condition, and contextual factors (personal and environmental factors). This definition would provide a uniform approach to the definitions of disability and functional status. In addition, if adopting the ICF framework, Functional Status and Cognitive Status would consider positive or neutral aspects of their domain as the definition of both use the term “functioning.” However, if ONC retains the existing definition of functioning, for consistency, the PACIO Community recommends including worsening/better in the Cognitive Status definition for USCDI v.4.
    • To maximize the utility of the data exchanged during transitions of care, the PACIO Community recommends including the questions and answers, expressed using LOINC, for the Functional and Mental/Cognitive Status data elements that are part of the federally required PAC assessment instruments, not just what functional or Mental/Cognitive assessment was performed. 

AOTA's Comment on Mental Function

The American Occupational Therapy Association supports and appreciates the inclusion of mental functions in the health status data class. AOTA participates in the PACIO Project work on the Cognitive Status Implementation Guide that has since been renamed to Functional Performance. Developing an interoperable and interdisciplinary method of collecting information on an individual's mental functions is crucial in early detection of cognitive decline, onset of delirium, or identification of trends over time. AOTA encourages ONC to consider how this data can be efficiently and accurately collected beyond admission and discharge and how data from other clinicians, such as occupational therapy practitioners, can be utilized in this data class.  

2022 USCID Final Comments_2.pdf

Mental Health as a class.

NACHC is supportive of the concept of mental function; however, it is not likely to support interoperability to solely create a terminology binding to support the concept. Because the concepts in the draft version generally represent non-semantically equivalent types of cognitive function and observations about these conditions, we believe that creating a class for this concept will likely create larger transitions of care documents without being able to be processed by receiving systems.

Furthermore, there will likely be confusion between which assessments constitute “Functional Status” and “Mental Function”. Would recommend renaming this term. This approach creates liability for providers who at best can use this data as free text in this case and contributes to data overload and burnout.

We strongly recommend providing either specific categories of functional status with equivalent semantics and clear terminology bindings.

2022-04-30 NACHC USCDIv3 Letter of Support_1.pdf

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