Data Element

Comment

CMS-CCSQ Support for Removing Pressure Ulcer Risk and Fall Risk

CMS suggests removing pressure ulcer risk and falls risk as examples under the Functional Status data element definition as they are not representative of functional status. Examples that can be added to this data element include self-care including activities of daily living, mobility, or use of a device. We agree that pressure injuries and falls risk information are important to exchange so we will address the placement of this information under the Problems data class in a future version of USCDI.

PACIO Project Recommends Removal of Disability Status

  • Data Class: Health Status Assessments (Draft V4) 

  • Data Elements: Functional Status, Mental/Cognitive Status, Disability Status (Draft V4)  

  • Recommendation: Remove the Disability Status data element from the Health Status data class and instead add a new data element entitled, “Disability” to the patient demographic data class.  

  • Rationale: The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, with the goal of establishing a framework for the development of FHIR implementation guides to facilitate health information exchange. The PACIO Community supports CMS and CDC submission, which reflect their view that identifying a person with a disability does not necessarily have any bearing on how healthy a person is or the status of one’s health. However, collecting and transmitting data on disability in a standardized way alongside other demographic factors is vital to recognition of disability as a key component of identity and allows analysis of outcomes and conditions in an intersectional way, incorporating race/ethnicity, age, sex, and disability together for a more comprehensive understanding of patient demographics. 

PACIO Project Recommends Value Set Adoption

  • Data Class: Health Status Assessments (Draft V4) 

  • Data Elements: Functional Status, Mental/Cognitive Status, Disability Status (Draft V4) 

  • Recommendation: Adopt the value sets developed for the “Personal Functioning and Engagement” IG as part of the USCDI V3 updates to the U.S. Core IG to incorporate Functional Status and Cognitive Status data elements. 

  • Rationale: The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, with the goal of establishing a framework for the development of FHIR implementation guides to facilitate health information exchange. Functional and Mental/Cognitive Status are important data classes that have widespread use in all healthcare settings and sharing the content of standardized PAC assessments (some of which are federally required) with non-PAC providers (e.g., hospitals, physicians) would improve the quality of care and facilitate care coordination during transitions of care. These instruments use a consistent framework mapped to HIT standards for functional status, contain administrative and clinical patient data, can be considered as individual data elements (mobility, pressure ulcer, transportation, social isolation, etc.) or a “questionnaire” of grouped data elements together (MDS, OASIS, IRFPAI, FASI etc.) The PACIO Community wishes to update the ONC/USCDI with current efforts relating to several of the data elements under the proposed USCDI V4 data class of Health Status (Health Concerns, Functional Status, Disability Status, and Mental/Cognitive Status). The PACIO Community recognized the value of creating data models (like Gravity’s SDOH) that allow for expansion across multiple domains. As a result, PACIO created a new FHIR Implementation Guide (IG), “Personal Functioning and Engagement,” which consolidates PACIO’s prior published IGs (STU1) “Cognitive Status” and “Functional Status”. The PACIO group also is incorporating data elements of communication, swallowing, and hearing to the “Personal Functioning and Engagement” IG currently under development. Currently, the Personal Functioning and Engagement IG data structures focus on observation/ assessment data. However, the IG could include future expansion using additional resources as the work matures. The concept of “Personal Functioning and Engagement” encompasses both an individual’s abilities (positive strengths) and disabilities (impairments) across all types of functioning. The PACIO Community examined and incorporated the International Classification of Functioning, Disability and Health (ICF) as a conceptual framework that underpins this new PACIO Personal Functioning and Engagement IG. PACIO’s current work focuses on ICF “Body Functions” including mental functions, sensory functions (including hearing), voice and speech functions, and ingestion functions (swallowing). Current PACIO focus for ICF “Activities and Participation” functions include Learning and Applying Knowledge, Communication, Mobility, and Self-care.  

PACIO Project Comment on Pressure Ulcer Risk and Falls Risk

  • Data Class: Health Status Assessments (Draft V4) 

  • Data Elements: Functional Status (Draft V4)  

  • Recommendation: Remove the pressure ulcer risk and falls risk as examples under the Functional Status data element definition.  

  • Rationale: The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, with the goal of establishing a framework for the development of FHIR implementation guides to facilitate health information exchange. The PACIO Community supports the CMS submission, which suggests removing pressure ulcer risk and falls risk as examples under the Functional Status data element definition, as they are not directly representative of functional status. Examples that can be added to this data element include self-care including activities of daily living, mobility, or use of an assistive device. Under USCDI V3, activities of daily living currently is listed as an example under the “Disability Status” data element, which we have recommended be removed from the Health Assessments data class in a separate comment submission. Consistent with this recommendation, we recommend activities of daily living should be included as an example under the Functional Status data element. We agree that pressure injuries and falls risk information are important to exchange, so we recommend this information would be more appropriately captured under the Problems data class in a future version of USCDI. 

Support to Advance Functional Status

  • The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, with the goal of establishing a framework for the development of FHIR implementation guides to facilitate health information exchange. Functional and Mental/Cognitive Status are important data classes that have widespread use in all healthcare settings and sharing the content of federally required PAC assessments with non-PAC providers (e.g., hospitals, physicians) would improve the quality of care and facilitate care coordination during transitions of care. These instruments use a consistent framework mapped to HIT standards for functional status, contain administrative and clinical patient data, can be considered as individual data elements (mobility, pressure ulcer, transportation, social isolation, etc.) or a “questionnaire” of grouped data elements together (MDS, OASIS, IRF-PAI, etc.)
  • The PACIO Community wishes to update the ONC/USCDI with current efforts relating to several of the data elements under the proposed USCDI v.4 data class of Health Status (Health Concerns, Functional Status, Disability Status, and Mental/Cognitive Status). The PACIO Community recognized the value of creating data models (like Gravity’s SDOH) that allow for expansion across multiple domains. As a result, PACIO created a new FHIR Implementation Guide (IG), “Personal Functioning and Engagement,” which consolidates PACIO’s prior published IGs (STU1) “Cognitive Status” and “Functional Status”. The PACIO group also is incorporating data elements of communication, swallowing, and hearing to the “Personal Functioning and Engagement” IG currently under development. Currently the Personal Functioning and Engagement IG data structures focus on observation/ assessment data. However, the IG could include future expansion using additional resources as the work matures. The concept of “Personal Functioning and Engagement” encompasses both an individual’s abilities (positive strengths) and disabilities (impairments) across all types of functioning. The PACIO Community examined and incorporated the International Classification of Functioning, Disability and Health (ICF) as a conceptual framework that underpins this new PACIO Personal Functioning and Engagement IG. PACIO’s current work focuses on ICF “Body Functions” including mental functions, sensory functions (including hearing), voice and speech functions, and ingestion functions (swallowing). Current PACIO focus for ICF “Activities and Participation” functions include Learning and Applying Knowledge, Communication, Mobility, and Self-care.
    • The PACIO Community encourages ONC to consider adopting the value sets developed for the “Personal Functioning and Engagement” IG as part of the USCDI v.3 updates to the U.S. Core IG to incorporate Functional Status and Cognitive Status data elements.

AOTA's Comments on Functional Status

AOTA encourages USCDI to consider including assessments that assess activities of daily living (ADLs) and instrumental activities of daily living (IADLs) as these are critical elements of an individual's function. We would recommend utilizing tools that already have LOINC codes that assess function on a broader scale (e.g. FASI). The other assessments mentioned as examples are limited in scope and may not capture sufficient data to communicate an individual’s function beyond basic elements.  

We support the use of the CMS Data Element Library but encourage the utilization of other instruments. The post-acute care assessment instruments capture limited information on ADLs that may not provide a full picture of an individual's ability to function after discharge from facilities or after therapy services have ceased.  

 

2022 USCID Final Comments_0.pdf

A Class for Functional Status

NACHC supports the comments from Ann Phillips/IMO and suchen.

 

NACHC is supportive of the concept of functional status; however, it is not likely to support interoperability to solely create a terminology binding to support the concept. Because concepts in the draft version are in fact different types of functional status or causes of disability, 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.

 

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 category of functional status with equivalent semantics and clear terminology bindings.

 

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_3.pdf

Functional status with needs beyond post acute care

Functional status assessments are commonly used in healthcare to document a patient’s baseline ability to manage daily routines and life activities. This assessment can be used as an indicator of quality of life (QOL) and help guide delivering patient-centered care. Functional status assessments are used broadly in healthcare, and can be used to:
* screen initially for problems, as well monitor the patient over time
* assess how a disease impacts a patient’s baseline functional status and their overall ability to tolerate certain therapies during serious illness

Functional status assessments can be generic or disease specific. For instance, in oncology, the Eastern Cooperative Oncology Group (ECOG) Performance Status assists in determining a patient’s potential chemotherapy tolerance.

A plethora of functional status assessment tools have been created to assist clinical management and are used broadly in medicine in fields such as oncology, palliative care, surgery, orthopedics, geriatrics, psychiatry, neurology, physical medicine and rehabilitation, nursing, etc. Achieving optimal patient outcomes for health and well-being requires an understanding of factors that affect quality of life (QOL), such as the ability of patients to perform basic activities and participate in life situations.

Please see attachment with similar prior submission regarding need for standardized "functional status" data.

This comment is made on behalf of CodeX (Common Oncology Data Elements eXtensions), a member-driven HL7 FHIR Accelerator community of professional medical societies, health systems, industry and others seeking to achieve interoperability via the mCODE (minimal Common Oncology Data Elements) standard in order to drive step-change improvements in cancer patient care and research.

Functional Status Assessment _ USCDI Version 3 Proposal.docx

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