Data Element

Comment

combined race and ethnicity

OMB recently finalized a proposal made about a year ago that combines race and ethnicity into a single concept, adds Middle Eastern and North African as a new major category, and offers the option to provide a more detailed ethnicity than currently captured among other changes. By the time USCDI v5 is likely to be used in regulation those changes will be several years along and likely starting to be absorbed/used in the real world. We suggest ONC consider whether it makes sense to adopt those changes in USCDI v5 or, if not, to at least consider a plan for how it will move to support those changes in the future.

CDC's Consolidated Comment for USCDI v4

  • Recommend updating the applicable standards language with the following: “At a minimum, the Office of Management and Budget Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity, Statistical Policy Directive No. 15, as revised, October 30, 1997, must be used. If needed, a detailed list of race and ethnicity categories must be captured using the CDC detailed Race and Ethnicity code system (CDCREC). The CDCREC detailed concepts are an expansion of and roll-up to the OMB minimum race and ethnicity categories. “
  • Comments from NACCHO: NACCHO supports addition of this data element. NACCHO recommends using the existing the HL7 standard for the Ethnicity.
  • Comments from CSTE: CSTE agrees with CDC's recommendation to align with CDC Race and Ethnicity Code System (see: PHIN VADS). Regarding implementation, if EHRs cannot display all coded values, they should have a mechanism to convert data into coded values in a way that meets jurisdictional reporting requirements. Additional revision may be necessary as OMB revises Statistical Policy Directive 15 (Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity).

CDC's comment on behalf of ASTHO (WA DOH)

Comments: Recommending addition of two values in the valueset ‘PHVS_EthnicityGroup_CDC’ that does not currently encompass the fact that patient do not respond to the question:

  • Hispanic or Latino
  • Not Hispanic or Latino
  • Patient declined to respond/Asked but unknown*
  • Unknown*

*New values being proposed

These comments apply to both…

These comments apply to both Ethnicity and Race. In USCDI v2, the recommendations for Ethnicity and Race require BOTH OMB Statistical Policy Directive No. 15 (10/30/1997) and CDC Race and Ethnicity Code Set Version 1.0 (March 2000). Two comments. First, the OMB and CDC terms appear to be the same, so it seems redundant to "require" both. Second, according to PHIN VADS, the CDC Race & Ethnicity codes are on version 1.2 as of 7/15/2021. I don't know what specific codes changed between versions 1.0 and 1.2, but the general hierarchy has been in place for many years. It would seem reasonable to update the USCDI recommendations for Ethnicity and Race to include CDC Race & Ethnicity v1.2 (and remove mention of OMB if allowable to do so).

Also, VSAC has Ethnicity (2…

Also, VSAC has Ethnicity (2.16.840.1.114222.4.11.837) and Race (2.16.840.1.114222.4.11.7232) value sets at v1.2, but the PHIN VADS source goes deeper into the hierarchy and is the more robust source that I suggest we converge upon. Happy to hear other comments on this.

Additional values in the value set

Recommending addition of two values in the value set ‘PHVS_EthnicityGroup_CDC’ that does not currently encompass the fact that patient do not respond to the question:

  • Hispanic or Latino
  • Not Hispanic or Latino
  • Patient declined to respond/Asked but unknown*
  • Unknown*

*=New values being proposed

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