Submitted by NCQA on
NCQA Comment on Pronouns: for USCDI v5
- Pronouns:
NCQA supports adding the Pronouns element to USCDI (as proposed by Gender Harmony and represented in LOINC through “Observation: 90778-2 Personal Pronouns – Reported” and “Answer list: LL5144-2 Personal pronouns 1.3.6.1.4.1.12009.10.1.4011”). Understanding which pronoun(s) to use when referring to someone is important for providing affirming health care. It is important to reliably exchange personal pronouns that the individual has specifically reported they want used.
Submitted by nachcinformatics on
Patient Identifying Information
NACHC agrees with the comments listed below. Patient Interpreter, Patient Preferred Name and Patient Pronoun are all key patient-centered concepts that support care teams in understanding and being responsive to patient culture and identity. We agree with the more detailed HL7 comments below.
Patient Demographics/Information: Interpreter Needed [New Data Element]
https://www.healthit.gov/isa/taxonomy/term/7903/draft-uscdi-v5
HL7 agrees that interpreters are needed and should be captured in provider electronic systems (i.e. EMR). Interpreters can assist providers with non-English-speaking patients in reviewing charts, scheduling appointments and care management.
HL7 observes that whether a patient needs an interpreter can also vary based on circumstance. For example, a Spanish-speaking patient that has an appointment with a specialist that only speaks English may need an interpreter. However, if that same patient has an appointment with their primary care physician who speaks Spanish, no interpreter would be necessary. Exchanging the patient’s spoken language proficiency allows systems to determine whether a patient needs an interpreter for specific appointments or encounters based on the language proficiency of the other participants. The spoken language proficiency is the proposed alternative, rather than written language proficiency, as the existing “Preferred Language” data element enables systems to determine what language is preferred for written materials.
HL7 recommends that ONC:
Patient Demographics/Information: Name to Use [New Data Element]
https://www.healthit.gov/isa/taxonomy/term/4586/draft-uscdi-v5
HL7 supports the inclusion of Name to Use in USCDI. We note that existing HL7 standards already support the exchange of this information.
Additionally, HL7 highlights that payer and provider specific systems may or may not have these Name to Use data elements captured currently. There is notable variance.
Patient Demographics /Information: Pronoun [New Data Element]
https://www.healthit.gov/isa/united-states-core-data-interoperability-uscdi#draft-uscdi-v5
HL7 supports the inclusion of Pronouns in USCDI. Our additional recommendations on this issue include recommending ONC:
Lastly, HL7 observes shared data should not replace a person’s name, but may offer a supplement. Both names and pronoun are not widely used nor included within systems. HL7 recommends that Caregiver(s) should also be included as a source of pronoun information.