NCPDP Comment

NCPDP recommends the adoption of taxonomy codes to identify the type of facility.

CMS-CCSQ/CDC Joint USCDIv4 Priority: Facility Type

CDC and CMS agree that facility type should move forward as part of USCDI V4. The facility type element complements existing USCDI data elements, particularly “encounter location”, and provides contextual information for surveillance, compliance, and public health action. For example, information on facility type can help facilitate work to improve health equity by supporting efforts to identify, characterize, and take steps to respond to evidence of decreased or restricted access to care, inadequate care quality, and adverse outcomes. However, we also recognize that applicable standards for facility type vary in terms of granularity, maturity, breadth (examples include NUCC Healthcare Provider Taxonomy—Non-Individual; NHSN Facility Type; FHIR Location). To that end, we recommend that ONC also work with CDC, CMS, and other key healthcare and public health stakeholders to identify and evolve appropriate standards for Facility Type. Importantly, standards for facility type should be defined in ways that maintain clear differentiation from “encounter location” and associated standards.

CDC's Consolidated Comment for USCDI v4

• Shared priority for CDC, CMS, and ASPR (via all hazards work with CDC)
• Why Facility Type Is Important: The facility type element provides contextual information for surveillance, compliance, and public health action. For example, facility type has been used during the COVID-19 response to set hospital reporting requirements and contextualize reported data on hospital burden and capacity. In addition, information on facility can help facilitate work on data equity. Some examples include different kinds of healthcare facilities (e.g., acute care hospital or SNF), correctional facilities, facilities that primarily serve people experiencing homelessness, and federally qualified health centers. When coupled with healthcare service and outcome data, we are better able to identify, characterize, and take steps to respond to evidence of decreased or restricted access to care, inadequate care quality, and adverse outcomes. Importantly, facility type complements existing USCDI data elements, particularly “encounter location”. One way to think about facility type vs. encounter location is that facility type is a “gross” characterization, like hospital, prison, SNF, or homeless shelter; encounter location, by contrast, is a more granular characterization of where services were delivered within that physical location (e.g., a trauma unit in an ACH, memory care ward in a SNF, infirmary within a prison). Another way to differentiate the two is by information use/purpose: Facility type can be thought of as a structural or administrative classification—it’s part of the “package” of electronic meta-data under discussion here and provides useful information for regulatory, payment, and certain healthcare quality and public health related actions. Encounter location is more functionally/clinically focused and more granular—as such, supports more nuanced distinctions of where care is provided and how that location “functions” that support quality measurement and improvement, as well as public health surveillance and situational awareness reporting purposes.
• Additional use case: hospital COVID-19 reporting:

As noted above, CDC and CMS agree that facility type should move forward as part of USCDI V4. However, we also want to recognize that applicable standards for facility type vary in terms of granularity, maturity, breadth (examples include NUCC Healthcare Provider Taxonomy—Non-Individual; NHSN Facility Type; FHIR Location). To that end, we recommend that facility type move forward with commitment to continue development, maturation of applicable standards for Facility Type Be defined in ways that maintain clear differentiation from “encounter location” and associated standards.

• Comments from NACCHO: NACCHO supports the inclusion of the facility type as the new data element. However, it recommends creating a standardized common table of facility types that can be used by agencies.
• Comments from CSTE: CSTE agrees with CDC's recommendation for this data element.

CDC's comment on behalf of CSTE for USCDI v4

CSTE agrees with CDC's recommendation for this data element. 

CDC's Consolidated Comment for USCDI v4

CDC continues to recommend inclusion of this high priority data element in USCDI v4.

Unified Comment from CDC

• Additional Use Case: This is a standard data item used by central cancer registries in all states. Data received through data exchange from medical facilities (e.g., laboratories, hospitals, physician EHRs, etc.) to central cancer registries for CDC and NCI’s national cancer surveillance systems, as required by law.   
• CSTE supports inclusion of this measure into USCDI v3: Very useful for this information to be captured in some way and then subsequently used in reporting to PH.