Data Element

Information from the submission form

Mental Function
Represents observations related to a patient's current level of cognitive functioning, including alertness, orientation, comprehension, concentration, and immediate memory for simple commands.


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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