Comment

Submitted by jenna.stern on 2022-04-29

Vizient comments SDoH

Outcomes: Vizient agrees with the use case description submitted to ONC by the Gravity Project. Overall, addition of the Outcomes element would allow for enhanced measurement of SDoH interventions, which may then also be used in the context of quality measurement. Also, the addition of an Outcomes element would allow for a more complete information, as currently available SDoH elements, which are included in different data classes, do not include outcomes (e.g., SDoH Assessment, SDoH Problems/Health Concerns, SDoH Goals, SDoH Interventions).

Submitted by JoshCaplan on 2020-12-23

Gravity Project ONC USDCI SDH

December 23, 2020                                          The Honorable Donald Rucker, M.D. National Coordinator for Health Information Technology U.S. Department of Health and Human Services 330 C Street SW, 7th Floor Washington, D.C.  20201   Re:   The Gravity Project’s Submission To Include Social Determinants of Health (SDOH) in the U.S. Core Data for Interoperability, Version 2, for Better Care and Better Health Nationwide   Dear Dr. Rucker: AcademyHealth welcomes the opportunity to provide input to the Office of the National Coordinator on behalf of the Gravity Project’s recent submission to include social determinants of health in the U.S. core data for interoperability. We are the professional home of more than 3,000 health services researchers, policy experts, and practitioners, and we strongly support the production, dissemination, and use of evidence to inform policy and practice. Our membership is highly engaged with research on racial/ethnic disparities that has helped to shape and produce the evidence base on the role of social determinants in predicting individual and population-based health outcomes as well as the healthcare costs associated with social and economic risks. We are aware of the limitations of the current data infrastructure for health services research and population health analytics and we applaud the work of the Gravity Project to strengthen the research community’s capacity for data-sharing and interoperability by introducing standardized data elements for SDOH.  The Gravity Project grew out of recognition by a broad group of stakeholders, including AcademyHealth, that a coordinated strategy for achieving standardized data for SDOH capture in electronic health record (EHR) systems was urgently needed.  AcademyHealth’s Vice President for Evidence Generation and Translation, Margo Edmunds, PhD, FAMIA, provided strategic advice in early meetings with key stakeholders during the planning stages for the Project and has served as a member of its Strategic Advisory Committee as the Project has evolved.     Since its creation, the Gravity Project has provided critical leadership in convening appropriate stakeholders and coordinating a structured, efficient, and comprehensive approach to:  
  • Understand the value and use of SDOH data for clinical care and population management;
  • Analyze gaps in existing terminology and codes used to represent SDOH-related activities in clinical delivery settings;
  • Develop standard terminology, vocabulary, and codes to refer to and implement SDOH concepts in the EHR context.
    Experts have long known that social and environmental determinants of health explain most of a person’s and population’s health status.  For the past nine months, the COVID-19 pandemic has highlighted this reality daily across the nation.  The Gravity Project’s submissions would add critical domains such as food insecurity, housing instability, transportation insecurity, social isolation, and stress to the USCDI, integrated with core clinical activities such as assessments, diagnoses, interventions, and outcomes.  Increasing the specificity of data in these domains will not only improve patient care and the care experience for providers and patients but also will greatly improve the quality of data used to track, predict, and eliminate health disparities.  Through AcademyHealth’s previous work leading the AHRQ-funded Electronic Data Methods Forum, we became acutely aware of the variability of EHR data in clinical settings and the challenges in aggregating and integrating data in service of large, multi-sector and multi-site data efforts to help address fundamental questions of policy and practice.  Standards for reporting SDOH will not only provide the data needed to drive improvements in patient care, but they will enable a clear record and justification for future financing based on careful health services and policy research and analysis.   Thank you for the opportunity to provide these comments for consideration.  AcademyHealth looks forward to working with ONC and with our colleagues at Gravity Project and other stakeholders to achieve the national policy goals of HHS as articulated in the Triple Aim.    If you have any questions, please feel free to reach out to Margo Edmunds, PhD.   Sincerely,   Lisa Simpson, MB, BCh, MPH, FAAP President and Chief Executive Officer   Cc:       Steven Posnack, Deputy National Coordinator for Health Information Technology             Elise Anthony, Executive Director, Office of Policy       

ONC Gravity Project AcademyHealth.pdf

Submitted by MaraSchwartz on 2020-12-21

Gravity Project ONC USCDI SDH

The attached letter of support is submitted on behalf of Lyft from Nicole Cooper, DrPH, MPH Head of Healthcare Policy. Gravity Project ONC USCDI SDH is key to Lyft Healthcare's mission of helping people in the US get access to best transportation possible in order to reach their critical medical appointments. Every year, 3.6 million American's miss their medical appointments due to transportation challenges. Gravity Project ONC USCDI SDH is a critical step in ensuring these patients and more are able to get the care they need.

Lyft to ONC on SDOH Data Class for USCDI (12-10-2020) (1).docx.pdf

Submitted by Dansby on 2020-12-18

Letter of Support for Gravity Project

We represent organizations that are focused on treating comorbid chronic diseases. We are acutely aware of the importance of Social Determinants of Health and the role that the Gravity Project is playing to advance healthcare science and delivery capabilities.  We strongly support the Gravity Project with the attached Letter.

Vf Codentx Letter of Support for Gravity Project.pdf

Submitted by SHewner on 2020-12-18

The Gravity Project’s Submission To Include SDOH

  December 17, 2020   By electronic submission   The Honorable Donald Rucker, M.D National Coordinator for Health Information Technology U.S. Department of Health and Human Services 330 C Street SW, 7th Floor Washington, D.C.  20201   Re:    The Gravity Project’s Submission To Include Social Determinants of Health in the U.S. Core Data for Interoperability, Version 2, for Better Care and Better Health Nationwide   Dear National Coordinator Rucker:   My name is Dr. Sharon Hewner, and I am a faculty member at the University at Buffalo School of Nursing. My research focuses on using health information exchange (HIE) to facilitate care coordination during care transitions for high need/high cost individuals. My coordinating transitions project used a simple 12 -item screening tool to assess social and behavioral determinants of health (SDOH) in a single primary care practice. Inclusion of this data transformed the way the primary care practice functioned. However, a major gap remained in including SDOH as part of the health concerns in a care plan that can be shared across settings.   My current work expands the use of HIE to develop cross-sector care plans. I am working with the Buffalo City Mission (emergency shelter and medical respite) as a pilot site to use SBDH data to reduce emergency department recidivism. I see the work completed by the Gravity Project as critical to the success of integrating care across health, behavioral health and social service sectors. Furthermore, the Gravity Project has provided critical leadership in convening appropriate stakeholders and coordinating a structured, efficient, and comprehensive approach to:  
  • Understand the value and use of SDOH data for clinical care and population management;
  • Analyze gaps in existing terminology and codes used to represent SDOH-related activities in clinical delivery settings;
  • Develop standard terminology, vocabulary, and codes to refer to and implement SDOH concepts in the EHR context.
  On October 23, the Gravity Project submitted a new SDOH data class with eleven initial domains across key clinical activities integrating four leading code systems.    My research depends on interoperable language that includes SDOH included so you can use it for better care, especially as we work as a nation to address COVID-19 and health disparities related to homelessness.   Respectfully submitted,   Sharon Hewner, PhD, RN, FAAN Associate Professor hewner@buffalo.edu

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