Submitted by yale-coredQMRoadmap on
CDC and CMS-CCSQ Joint Support for Vaccination Event Record Type
Thank you for opportunity to comment on this data element. The Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC) emphasize the importance of patient safety being reflected in the USCDI standards. Identification of whether vaccinations are current and whether any vaccinations need to be administered using the Vaccination Event Record Type and Immunization Status data elements are vital to patient safety outcomes. CMS and CDC strongly recommend the Vaccination Event Record Type (Level 2) data element in the Immunization data class be added to USCDI. This addition would promote patient safety.
Submitted by BLampkins_CSTE on
CSTE Comment - v5
CSTE agrees with CDC and continues to strongly recommends that Vaccine Administration Date and Vaccination Event Record Type be included in USCDI v5. Both elements are required for immunization exchange and always have been. Each year, IIS respond to CDC’s annual report (IISAR). At the end of calendar year 2019, IIS records contained vaccine administration date 99.9% of the time with only 1 IIS reporting less than 100%. With these lacking from USCDI v5 draft, it would be possible to list only the immunization code a patient received, but not the date the patient received the dose or if the vaccination event originated in the source system. Vaccine Administration Date enables accurate record evaluation (e.g., were doses given at the proper age and at a proper interval) while Vaccination Event Record Type enable accurate inventory decrementing by public health and aids in vaccine matching/deduplication.