Facility Information

ANI's comment on USCDI v6: Facility address

The Alliance for Nursing Informatics (ANI) supports the inclusion of this data element and add our comments below. Please see previously submitted ANI comments for additional recommendations.

• Consider how this applies to mobile or EMS services, which may not be tied to a fixed address. Excluding EMS from facility-based exchange risks missing data about care delivery at the first point of patient contact. 
• Guidance should clarify how to represent facilities spanning multiple physical locations and therefore have multiple addresses or alternatively have no addresses (i.e., mobile/EMS services).

CSTE Comment - v6

CSTE supports inclusion of this data element in USCDI V6. Please see previously submitted CSTE comments for additional recommendations.

CMS-CCSQ Support for Facility Address data element for USCDI v6

Data Element: Facility Address (Level 2)

1. Recommendation: Add the Facility Address data element to Final USCDI v6.
2. Rationale: The Facility Address data element will supplement the core set of information necessary to identify facilities and link service and outcome data to a specific physical institution or facility. Currently, in the absence of a unique Organization/Hospital Identifier data element in the USCDI, it can be difficult to differentiate specific service locations and link data or records for public health and healthcare purposes, such as monitoring hospital capacity and respiratory disease burden in acute care hospitals, identifying and responding to outbreaks in facilities, and tracking patient safety events. Accurate facility information, including name, address, and identifier, is essential to analyze facility level data and inform the allocation of resources such as therapeutics, supplies, staffing, and personal protective equipment (PPE) to prepare for and respond to emergency events.

CSTE Comment - v5

CSTE agrees with CDC's recommendation for this data element. 

CDC's Comment for draft USCDI v5

CDC supports the inclusion of this data element in USCDI v5 as it is an element that may be necessary for calculation of our digital quality metrics from FHIR data.

CDC and CMS-CCSQ Joint Support for Facility Address

Thank you for opportunity to comment on this data element. The Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC) emphasize the importance of patient safety being reflected in the USCDI standards. Identifying facility information, such as Facility Address, is critical to differentiate specific service locations and link data/records for public health and healthcare purposes. CMS and CDC strongly recommend the Facility Address data element (Level 2) in the Facility Information data class be added to USCDI. This addition would promote patient safety.

CMS-CCSQ Support for Facility Address for USCDI v5

CMS-CCSQ recommends this Level 2 data element be added to USCDI v5. Together with the Facility Identifier, Facility Type, and Facility Name, the Facility Address data element will supplement the core set of information necessary to identify facilities and link service and outcome data to a specific physical institution or facility. This was previously identified as a joint CMS-CDC priority. Currently, in the absence of a unique Organization/Hospital Identifier in the USCDI, it can be difficult to differentiate specific service locations and link data or records for public health and healthcare purposes. Location information is routinely captured in EHR systems. Since Facility Names and Facility Identifiers (e.g., CCNs) can be shared by separately located facilities, Facility Address can provide critical identifying information to differentiate specific locations and accurately link data to optimally track care quality and health outcomes.

CDC's Consolidated Comment for USCDI v5

• The facility address is required in both Laboratory Domain and public health. In the laboratory domain, the test ordering facility address needs to be included in the data as required by the CLIA Regulation §493.1241(c)(1). The address of the test-performing laboratory is also required as indicated by the CLIA regulation §493.1291(c)(2). Test ordering facility is also an “R” or a required field in public health profiles in both Laboratory Orders Interface (LOI) and Laboratory Results Interface (LRI). We recommend inclusion of this element USCDI V5
• NAACCR comment: For cancer registry (and other public health) reporting, facility address is required to determine the jurisdiction with authority to collect and report the test and results.
• CSTE Comment: CSTE agrees with CDC's recommendation for this data element. 
• NACCHO Comment: Supports CDC's comment.

CMS-CCSQ/CDC Joint USCDIv4 Priority: Facility Address

Together with the Facility Identifier, Name and Type, the Facility Address data element will supplement the core set of information necessary to identify facilities and link service and outcome data to a specific physical institution or facility. Currently, in the absence of a unique Organization/Hospital Identifier in the USCDI it can be difficult to differentiate specific service locations and link data or records for public health and healthcare purposes, such as monitoring hospital capacity and respiratory disease burden in acute care hospitals, identifying and responding to outbreaks in facilities, and tracking patient safety events. Accurate facility information, including name, address, and identifier, is essential to analyze facility level data and inform the allocation of resources such as therapeutics, supplies, staffing, and PPE to prepare for and respond to emergency events.

CDC's comment on behalf of CSTE for USCDI v4

CSTE agrees with CDC's recommendation for this data element.