Comment

Do you intend the USCDI to support a multiaxial heirarchy?

If you make Orders a Data Class, then you need to decide if you will allow notions to be categorized in more than one place or not.  For example, orders for laboratory, pathology, and diagnostic imaging tests, should those data elements be covered in those respective data classes, or should those data elements be shown within the Orders data class?  Or should they show in both places?

CMS-CCSQ Support for Orders in USCDI v3

CMS-CCSQ  continues to support inclusion of the broader Orders data class to capture and exchange all orders for medical services (service requests). This information confirms appropriate and high-quality care is provided in quality measurement, is relevant information required to support a referral or a transfer of care request from one practitioner or organization to another, and is used for prior authorization activities.   CMS-CCSQ also recommends inclusion of an End of Life Care Orders data element defined as orders for hospice, palliative care, and comfort care. Rationale:  End of life care orders are especially critical for care coordination and care decision making. This concept may be used to share relevant information required to support a transfer of care request from one practitioner or organization to another that provides end of life care services, which often happen at different organizations. Interoperability of these orders would also allow orders to move more easily between organizations, facilitating patient choice. Maturity:
  • Current standards:
    • Orders can be exchanged in mature FHIR standards, including Service Request profile included in QI Core.
    • End of Life Care concepts are captured in mature terminology: LOINC, SNOMED
  • Current uses, exchange, and use cases: Orders (service requests) for end-of-life care services are routinely captured in EHR systems used by hospitals and providers and are used in CMS quality reporting eCQMs across programs including IQR, QPP, and Promoting Interoperability programs. CMS requires the submission of order (service request) related data for quality measurement for eligible hospitals/CAHs and clinicians using ONC Certified Health Electronic Record Technology (CEHRT)—this includes orders (service requests) for an intervention (i.e., palliative care, hospice, comfort care).

Support for orders and request for data model clarity

We support the USCDI TF and HITAC recommendations to prioritize medical orders for life sustaining treatment (POLST/MOLST) and End of Life Care Orders as noted by CMS-CCSQ. We also concur with Lisa Nelson's sentiment that additional thought should be given to the data model structure for representing orders more generally.

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