Data used to categorize individuals for identification, records matching, and other purposes.

Data Element

Tribal Affiliation
Description

Tribe or band with which an individual associates.

Comment

CDC's Consolidated Comment

  • CDC supports the ONC decision on adding the Tribal Affiliation data element (Demographics data class) to the USCDI v.3. Adding this data element to EHR provides an additional mechanism for the assessment of health status and organization health equity interventions for tribal populations. In addition it facilitates tribal access to data about their tribal members. Also, we support the CSTE and WA Department of Health comments on a necessity of a dialog with tribes to assure addressing privacy concerns of patients. Furthermore, we recommend the following changes so current and accurate information and references are used.

 

  • Because of absence this data element definition in the USCDI, we recommend the following definition:

The Tribal Affiliation data element provides the patient’ association by name with federally recognized Indian tribes or with federally recognized Alaska native villages/tribes within the state of Alaska.

 

  • Please update the Links to use case project page as the following:
  1.  Indian Affairs Bureau, https://www.federalregister.gov/documents/2022/01/28/2022-01789/indian-entities-recognized-by-and-eligible-to-receive-services-from-the-united-states-bureau-of  and
  2.  HL7 http://terminology.hl7.org/ValueSet/v3-TribalEntityUS (INDIAN ENTITIES RECOGNIZED AND ELIGIBLE TO RECEIVE SERVICES FROM THE UNITED STATES BUREAU OF INDIAN AFFAIRS)

 

  • Edit the Applicable Vocabulary Standard(s) as the following:
  1. LOINC 95370-3, Tribal Affiliation (for the question).
  2. The following standards for the answer: Indian Entities Recognized by and Eligible To Receive Services From the United States Bureau of Indian Affairs, 87 FR 4636, 01/28/2022 (https://www.federalregister.gov/documents/2022/01/28/2022-01789/indian-entities-recognized-by-and-eligible-to-receive-services-from-the-united-states-bureau-of) with added HL7 NullFlavor values: NI (no information), OTH (other), UNK (unknown), ASKU (asked but unknown).

 

  • Please add to the Supporting Artifacts the following:
  1. HL7 http://terminology.hl7.org/ValueSet/v3-TribalEntityUS (INDIAN ENTITIES RECOGNIZED AND ELIGIBLE TO RECEIVE SERVICES FROM THE UNITED STATES BUREAU OF INDIAN AFFAIRS)

 

 

Comment from CSTE:

  • Tribal affiliation (draft V3); The collection, usage, management, disclosure, and safeguarding of Tribal data is a governance activity that ONC should develop in collaboration with the Tribe(s) whose members are included in the data. The ONC should commit to meaningful consultation with tribal leaders of individual sovereign tribal nations to ensure they have an opportunity to provide timely input before using Tribal data, including Tribal affiliation or any other Tribal identifying information. The U.S. Constitution recognizes that Tribal nations are sovereign governments. As such, they have powers of self-government, upheld, repeatedly, by the U.S. Supreme Court. Tribal governments have the legal authority to administer the collection, ownership, application, and interpretation of their own data, even if it is collected by federal, state, or local governments. Tribal data means public or private facts, statistics or items of information on or about a Tribe or its people subject to tribal rights of ownership and control. This includes, but is not limited to, Tribe of membership, Tribe of affiliation, and identification of tribal facilities, entities, and enterprises. Tribal data means (1) data that is specific to an individual Tribe; or (2) data that is specific to more than one Tribe but does not identify individual Tribe(s).

 

Comment from ASTHO (WA DOH):

 

  • The collection, usage, management, disclosure, and safeguarding of Tribal data is a governance activity that ONC should develop in collaboration with the Tribe(s) whose members are included in the data. The ONC should commit to meaningful consultation with tribal leaders of individual sovereign tribal nations to ensure they have an opportunity to provide timely input before using Tribal data, including Tribal affiliation or any other Tribal identifying information. The U.S. Constitution recognizes that Tribal nations are sovereign governments. As such, they have powers of self-government, upheld, repeatedly, by the U.S. Supreme Court. Tribal governments have the legal authority to administer the collection, ownership, application, and interpretation of their own data, even if it is collected by federal, state, or local governments. Tribal data means public or private facts, statistics or items of information on or about a Tribe or its people subject to tribal rights of ownership and control. This includes, but is not limited to, Tribe of membership, Tribe of affiliation, and identification of tribal facilities, entities, and enterprises. Tribal data means (1) data that is specific to an individual Tribe; or (2) data that is specific to more than one Tribe but does not identify individual Tribe(s).

 

 

 

NACHC believes tribal…

  • NACHC believes tribal affiliation is foundational component of patient identity and required for patient-centered care.
  • We strongly support the use of the code systems and codes described by the Tribal Entity code systems to ensure robust and patient-centered support for patients with tribal affiliation in the US healthcare system.

Please see attached NACHC letter, documenting this comment and other feedback for v3 accepted draft data elements.

2022-04-30 NACHC USCDIv3 Letter of Support_8.pdf

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