Comment

Oregon Health Authority ISA Comments

Oregon has implemented standards for the collection of Race, Ethnicity, Disability, and Language (REALD). State legislation in 2013 (HB 2134) required OHA and the Oregon Department of Human Services (ODHS) to develop standards in all programs that collect, record, or report demographic data. It is critical to collect these data in a consistent and standardized manner to assess how racism impacts community and individual health. While we aim to align state standards to national standards where possible, specific to race and ethnicity, the CDC v1.0 standard is not inclusive enough and is missing two races that are collected, recorded, and reported in Oregon – Somali and Slavic. We are unclear on the pathway to recommend changes to the CDC standard and if approved the time for the standard to be updated. We encourage ONC to deploy a clear path and forum for states to use when updates to national standards for demographics data are needed.

OHA ISA Comments on letterhead_.pdf

Changes to the CDC Standard on Race and Ethnicity

ONC continues to work with our federal partners on refining standards related to demographic data. This is an area that will continue to evolve over time.

Difficult to know what the…

Difficult to know what the CDC specification is: I could find no enumeration of the possible codes in the proposal. This makes it hard to know what is intended and why. Something clearer should be produced before asking respondent to comment. The current OMB is clear regarding the top 5 and the extension The proposal has a lot of content regarding options for entering more than one race (but thought that capability was available in current race specification).

What Use Case Does LOINC Support?

What use case does LOINC support that is not currently supportable with existing implementations?  We are concerned about adding additional complexity for implementing an additional value set that does not align.

This is good.

This is good.