United States Core Data for Interoperability (USCDI)

Comments from Wolters Kluwer

Attached are comments from Wolters Kluwer on USCDI v.4. Thanks for allowing us to share our views

WK Comments to ONC on USCDI Version 4 September 2022 Final.pdf

OCHIN Comments on draft USCDI Version 4.

Thank you for the opportunity to comment. Please see attached for the comments from OCHIN on consideration for version 4. 

HHS ONC Comments on draft USCDI Version 4.pdf

CMS-CCSQ Submission for USCDI Version 4 Recommendations

On behalf of The Centers for Medicare and Medicaid Services (CMS) and The Center for Clinical Standards and Quality (CCSQ), we submit the following recommendations for the USCDI version 4 consideration. CMS encourages continued expansion of the USCDI to include high priority data elements necessary to support nationwide interoperability. This expansion will support clinical care, care coordination and quality improvement, while easing the burden of quality measurement. We are committed to continuing our collaborative work with the Office of the National Coordinator for Health Information Technology (ONC) and other federal partners to ensure the USCDI meets stakeholder needs and to ensure the USCDI is the central mechanism in defining the foundational set of electronic health information for interoperable health information exchange. We specifically continue to urge ONC to add additional data elements outlined below to the USCDI v4 which support high priority areas identified by ONC, including: mitigating health and healthcare disparities; addressing the needs of underserved communities; and addressing public health interoperability needs. We have also entered comments for each recommendation in the ONDEC system. The elements highlighted have continued to be CMS priority, previously raised for consideration for prior USCDI versions. We thank ONC for the opportunity to provide comments and priority data element recommendations for USCDI v4. We recognize there are many elements under consideration and aimed to focus recommendations on data elements with widespread use cases across providers, payers, and patients that are critical for exchange to improve patient care and outcomes.

CMS-CCSQ USCDI v4 Submission Letter_0.pdf

Advance Directives data class at Level 2, but missing from page

The Advance Directives data class is at Level 2, but is missing from the Level 2 USCDI page.  It appears on the Level 1 USCDI Page with data elements that are at Level 1, and there the Advance Directives data class is clearly labeled as being at Level 2.  This is confusing.     Recommendation: Update the Level 2 page to include an empty box (no Advance Directives data elements at Level 2), but shows that the data class itself is at Level 2.

Linking elements in the USCDI to FHIR Resources

Has ONC produced any documents that tie elements in the USCDI to specific "resources" in the FHIR API specs? For example, what resource in FHIR would we use to grab the reason (and date) of each outpatient encounter (in office or telehealth)?

Assessment and Plan

I see that this version still contains a vague concept that is impossible to produce electronically in any kind of measurable way: Assessment and Plan. Typically, the assessment and plan section of documentation is created as prose at the end of a progress note. Progress notes are already included in USCDI. Requiring “assessment and plan” as a USCDI data element is redundant and confusing. Assessment and plan as a data element does not exist as data in any EHR system I am aware of. Please consider eliminating or explaining what this “data element” is.

USCDIv3_Comments.docx

DREDF Comments on USCDI v3

Please see attached the comments of Disability Rights Education and Defense Fund (DREDF) on USCDI v3.   Thank you, Silvia Yee

DREDF Comments_USCDI v3_4-30-22_0.docx

This field is for general…

This field is for general comments on the USCDI. To submit new USCDI data classes and/or data elements, please use the USCDI ONDEC system: https://healthit.gov/ONDEC

DREDF Comments_USCDI v3_4-30-22.docx

HL7 Patient Empowerment PCD feedback on USCDI v3 and provenance

USCDI consists of categories of data elements representing information captured from different systems as well as by individuals. However, attribution of information created or supplied by an individual, as a patient or other role, is not reflected within the Provenance data class in the latest USCDI draft version 3 consisting of the following two (2) data elements: Author Time Stamp and Author Organization. We suggest at minimum the Author data element classified as Level 2 be added to USCDI v3.    In addition to USCDI v3 Provenance not specifying Author, the data class is not fully inclusive of information created outside an organization (or changes to information such as updates). To better understand the origin and changes to data that can occur with or without exchange, and improve Provenance with context that identifies the type of actor or system creating or updating data, we recommend two (2) additional data elements: 

1. Author Role to clarify the type of actor, such as patient, especially where information is contributed by individuals. Author should also accommodate device-generated data such as wearables. 
2. Updates to understand whether data has changed either from the point of creation or in exchange

  We also suggest ONC reframe Author Organization to be location-agnostic or account for environments outside an organization which may include a personal device or system.   COVID-19 pushed care delivery outside organizations with a boom of consumer-facing technologies to enable remote care and support emergent public health priorities. The pandemic also highlighted the need to understand factors outside of healthcare settings that have a large effect on health status (and outcomes). However, the current USCDI does not explicitly represent health and other data that might be contributed by individuals outside health care organizations, in spite of introducing new data classes and elements often dependent on individual/patient input. Several current or potential future data clases contain elements often asserted or informed by the patient including (but not limited to):   

• Demographics (include identity, race and ethnicity, sexual orientation and gender identity, and other data)
• Health Insurance Information
• Goals (Patient and SDOH)
• Problems (includes SDOH Problems/Health Concerns and dates from diagnosis and resolution)
• Health Status (Includes Health Concerns, Functional Status, Disability Status, Mental Function, and Smoking Status)
• Clinical Tests (currently only reflects those performed in lab though perhaps could be expanded to include self-administered at-home tests)
• Observations
• Assessments and Plan of Treatment (includes SDOH assessment)
• Advance Directives (not in USCDI v3)
• Vital signs (e.g. where capture from remote sensing devices)

  We see patient contributed data which is person-generated or self-reported as equivalent to clinical and administrative data recorded by health care professionals or systems. Therefore supporting provenance that captures the most granular metadata associated with data creation in USCDI is foundational for all information contributed by patients to be recognized and trusted.    As ONC continues to prioritize health equity and patient engagement, the importance of data provenance will only increase as USCDI evolves and information used to identify, assess, treat, coordinate, and measure care increasingly relies on patient generated or contributed information. Updating the USCDI to ensure instances where data originate or are reported by individuals are appropriately attributed is a first step in ensuring PCD is recognized, represented, and leveraged to improve patient engagement, promote equity, and support broader national health care and interoperability goals.   Thank you for considering HL7 Patient Contributed Data (PCD) Committee (Sub-Workgroup of the HL7 Patient Empowerment Workgroup) comments in finalizing the USCDI v3.  

American Occupational Therapy Association's Comment on USCDI v3

The American Occupational Therapy Association (AOTA) appreciates the opportunity to comment on draft version 3 of the US Core Data for Interoperability (USCDI). AOTA is the national professional association representing the interests of more than 220,000 occupational therapists, students of occupational therapy (OT), and occupational therapy assistants. Occupational therapy defines “occupations” as any meaningful or purposeful activity, which can describe activities of daily living (ADLs), instrumental activities of daily living (IADLs), work, school, hobbies, and social participation. The practice of occupational therapy is person-centered, evidence-based, and enables people of all ages to live life to its fullest by promoting health and purposeful activity. AOTA believes that understanding a person’s whole health, including function, environment, and context is crucial.  AOTA is pleased to see the addition of Health Status as a data class. We support the inclusion of health concerns, functional status, disability status, mental function, pregnancy status, and smoking status as key components of health status. AOTA encourages these items to also be aligned with social determinants of health as these factors can have a significant impact on an individual’s status.  We also support the utilization of the International Classification of Function (ICF) when establishing a framework for health data exchange in regards to function, cognition, and mobility. The Occupational Therapy Practice Framework: Domain and Process –4th edition (OTPF4) was developed based on concepts and terminology from the ICF in an effort to promote standardized interdisciplinary communication.     Please see attached for full comments from AOTA

2022 USCID Final Comments.pdf