|Submitted By: Joel Andress / Centers for Medicare and Medicaid Services (CMS) Center for Clinical Standards and Quality (CCSQ)|
|Data Element Information|
|Rationale for Separate Consideration||USCDIv1 only requires BMI percentile for ages 2-20. Recommend expanding to include BMI (as a number) for the adult population. USCDIv1 also requires all data necessary to calculate a BMI (age (DOB), birth sex, height and weight) but not BMI.|
|Use Case Description(s)|
|Use Case Description||BMI for adults is used in quality measurement among CMS quality measures in IQR and QPP. As obesity is a challenge for adults in the united states, this important vital sign is captured for assessment of appropriate care for those adults with certain BMI levels.|
|Estimated number of stakeholders capturing, accessing using or exchanging||Providers participating in CMS quality reporting programs (QPP) currently capture, access and exchange BMI results (or associated data elements for calculation) in the adult population.
eCQI resource center, includes measure specifications for CMS program eCQMs: https://ecqi.healthit.gov/ecqms (i.e. CMS 771)
|Link to use case project page||https://ecqi.healthit.gov/ecqms|
|Maturity of Use and Technical Specifications for Data Element|
|Additional Specifications||HL7 FHIR US Core Implementation Guide STU3 based on FHIR R4, Observation Vital Sign BMI Profile, http://hl7.org/fhir/R4/bmi.html
HL7 FHIR QI Core Implementation Guide STU4 based on FHIR R4, Observation Profile http://hl7.org/fhir/us/qicore/StructureDefinition-qicore-observation.html
CMS Quality Data Model (QDM) version 5.5 Guidance, physical exams performed (https://ecqi.healthit.gov/sites/default/files/QDM-v5.5-Guidance-Update-May-2020-508.pdf)
HL7 C-CDA Release 2.0 (http://www.hl7.org/implement/standards/product_brief.cfm?product_id=492)
|Current Use||Extensively used in production environments|
Vital signs widely available in EHR systems. BMI, based on standard terminology, supported in observation profiles in EHR systems. Used in CMS measurement, and therefore captured by providers participating in quality reporting programs.
|Number of organizations/individuals with which this data element has been electronically exchanged||5 or more. This data element has been tested at scale between multiple different production environments to support the majority of anticipated stakeholders.|
Vital signs, including adult BMI results are electronically exchanged for quality measurement used across CMS programs via QRDA files and other file architecture.
Vital Sign data can also be electronically transferred via C-CDA for clinical care coordination
|Restrictions on Standardization (e.g. proprietary code)||No challenges anticipated|
|Restrictions on Use (e.g. licensing, user fees)||None|
|Privacy and Security Concerns||This data, like any patient data, should be exchanged securely. Current processes exist, governed by CMS and ONC, to securely transfer this data.|
|Estimate of Overall Burden||Minimal burden estimated; BMI used for quality measurement, and associated data elements needed for calculation already required by USCDI v1|
|Other Implementation Challenges||N/A|
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
Information from the submission form
Submitted by jdamore on 2020-10-24
Support to Advance BMI in USCDIThis comment is in support of the advancement of Body Mass Index (BMI) in the United States Core Data for Interoperability. As part of a research project sponsored by the National Committee of Quality Assurance (NCQA) and a regional health information exchange in New York, Diameter Health was requested to examine data included in clinical documents, such as C-CDA, for 474 distinct facilities in 2020. These clinical documents are shared through health information exchange with other healthcare organizations routinely, in part to fulfill requirements for use of certified health information technology to record and transmit data related to USCDI. These facilities represented a mix of ambulatory care, inpatient and post-acute settings in New York. The project was sponsored as part of the emerging program for Data Aggregator Validation (DAV) launched by NCQA (https://www.ncqa.org/programs/data-and-information-technology/hit-and-data-certification/hedis-compliance-audit-certification/data-aggregator-validation/). These comments represent the perspective of Diameter Health and are not meant to represent the opinions, perspectives or policy of any other organization. Over the data analysis of 474 organizations having sampled 100 clinical documents from each, Diameter Health found that most organizations recorded and transmitted BMI information as part of care encounters. This information was available on approximately 60% of patient records and was shared on at least some patients for over 80% of facilities. This information was virtually always sent with the appropriate LOINC code. BMI has been historically included as part of the standard vital signs expected in clinical documents. HL7 validated examples already show the appropriate way to record and transmit this information (http://cdasearch.hl7.org/examples/view/Vital%20Signs/Panel%20of%20Vital%20Signs%20in%20Metric%20Units) Diameter Health works with over 20 health information exchanges nationally as well as an array of health plans, health information technology vendors and governmental entities. The findings shared as part of this research supports observations from other clients. Diameter Health strongly supports the continued elevation of BMI in the USCDI and we believe that the data from the field shows that this information is already widely recorded and exchanged among healthcare organizations. Please feel welcome to reach out if it would be helpful to share more details or to answer questions regarding this comment.