Facility Information

ACLA Comment for USCDI v6: Facility Address

The American Clinical Laboratory Association (ACLA) appreciates the opportunity to comment on the Facility Address. We would like to express our support; however, ACLA believes that this requirement would need more validation. We would like to understand how this requirement would apply to remote (including global) workers.

CDC's Comment for draft USCDI v6

CDC has recommended inclusion of this field since USCDIv4 supporting a number of applications. 

Facility address is an important piece of information for deaths, births and fetal deaths that occur in health care settings and are reported via an EHR, so support for a facility address data element as a core element would be beneficial. 

Deaths in Hospital: 
The place of death for in-hospital deaths may be provided by a funeral director or the medical certifier. Since medical certifiers may document place of death, it would be useful to have facility information as a core data element within the medical certifier’s EHR. 

Births and Fetal Deaths in Healthcare Settings: 
Most births and fetal deaths occur in a hospital or other health care facilities like birthing centers or clinic/doctor’s offices. When the mother or infant are transferred to another facility, the address of that facility also needs to be recorded. 

Sources: U.S. STANDARD CERTIFICATE OF DEATH -- REV. 11/2003; Physician’s Handbook on Medical Certification of Death; Facility Worksheet for the Live Birth Certificate

Additionally, 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 strongly support including this element USCDI V6.

Furthermore, CDC is requesting an Organization/Hospital Identifier data element be included as part of Facility Address. Explanation to request an Organizational Identifier.
 
The National Health Care Surveys includes two separate surveys: National Hospital Care Survey and National Ambulatory Medical Care Survey (NAMCS)

Facility Identifier: National Hospital Care Surveys would benefit from a Facility Identifier because they sample at the hospital level (i.e. the hospital from the sampled location is the only site of interest) and it is associated with the physical place of available services or resources.
 
The recommendation differs for NAMCS Health Center Component who samples at the health center level (i.e. every subsidiary care delivery site under the sampled health center is sampled along with the health center). For that reason:

Facility Managing Organization Identifier: NAMCS Health Center Component samples all care delivery sites under the sampled health center. To increase NAMCS quality control it would be helpful to receive Facility Managing Organization Identifier, as it is associated with health care provider locations and ambulatory providers.

CMS-CCSQ Supports Facility Address's inclusion in USCDI v6

Comment: CMS CCSQ supports the inclusion of "Facility Address" in USCDI Version 6 as it will supplement the core set of information necessary to identify facilities and link service and outcome data to a specific physical institution or facility.

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.