Submitted by CaseyThompson on 2021-04-14 Clinovations GovHealth USCDI Draft V2 Comments: Provenance Considerations for provenance attributed to discrete structured data The Author Time Stamp and Author Organization data elements are important for payloads exchanged, but they are also critical for the discrete, structured data that reside in exchanged payloads. We raise the consideration of how to evolve the USCDI to support attribution to a specific provider or organization through provenance retained for specific data that may be reconciled. Without the capability to see the original author time stamp and organization for problems, medications, allergies, and other structured data, providers are likely to continue experiencing hesitation to retain provenance or insight into whether external data is reconciled. Today, practices vary across health IT developers with regard to reconciled data. Some solutions attribute reconciled data with the individual performing the reconciliation, while others retain the provenance / attribution of the external data. In addition, when generating a C-CDA or using FHIR to exchange USCDI data within an enterprise, multi-specialty organization to send or make available for a 3rd party, will provenance be at the document level for all problems and medications while different specialties may be managing different conditions or medications?