Comment

Clarification on appropriate use of RSSG

Per the Gender Harmony Project as discussed and voted on 2023-04-17.

The Gender Harmony Project has significantly clarified our approach for Recorded Sex or Gender.  The approach is to treat RSG as a methodology for exchanging existing data, rather than as a data element itself.  RSG is not intended to be an exchanged element.  Rather, it is a methodology for exchanging context specific sex or gender values that already exist in medical or administrative systems.  It does not seem appropriate to name a methodology within USCDI, so we recommend that RSG be removed from USCDI (Level 2).  Instead, the output of that methodology, when sufficiently defined and adopted by the industry, MAY be useful to include in USCDI.  For example, if Claims were added as a data class in USCDI, then it may be appropriate to include the sex from the claim as a data element, where that sex is the output of the methodology.

For these reasons, the Gender Harmony Project recommends that:

  • Move the existing (Level 1) Recorded Gender for Health Insurance into the Health Insurance Information data class.
  • Remove RSG as a Level 2 Data Class and Data Element. 
  • As future data classes are added (e.g., Claims), consider including a Claims Sex (a type of Recorded Sex or Gender) data element within that data class.

We are not aware of any systems that exchange Recorded Sex or Gender as a stand-alone concept as modeled by the Gender Harmony Project.  However, we expect many systems are exchanging recorded sex or genders in support of other data classes, for example, as part of a Prior Auth request or a Claim submission.

RSG should not be a "general" exchanged data element

While there is broad industry implementation of Administrative Gender and Sex assigned at birth (SAAB), there is also wide agreement that the meaning of these data elements is suspect and they can be dangerous if used when the meaning is unclear. But in addition to those prominent recorded sex or gender values, there are many other sex and gender values in clinical and administrative documentation.  These other sex and gender values are usually captured within a context, such as a health insurance application or claim, but even then, the meaning may only be known to the individual completing the form and should only be used in the context of that form or data environment. Because of this deep contextual alignment and use, we are concerned that by making a general USCDI data class for RSG, implementers may believe that there is a need to identify and potentially exchange individual RSG values outside of the context they were collected.  The Gender Harmony project does not suggest and is not supportive of the exchange of RSG elements. What is useful is to identify sex or gender elements in other USCDI data classes and clearly identify them as a context specific RSG within the data class. A new data element of “Recorded Gender for Health Insurance'' in the Health Insurance Information would be an example of this. 

Recommendation:

  • The Gender Harmony project does not suggest and is not supportive of the exchange of generic RSG elements.
  • Gender Harmony will submit a separate ONDEC proposal for “Recorded Gender for Health Insurance” in the Health Insurance Information.

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