Submitted by Riki Merrick on
APHL requests inclusion of this critical element in V6
APHL recommends to add this element to V6 as this is a critical element for linking patients within organizations, and every organization assigns some form of patient identifier to their patients. It is also called out in CLIA regulation 42 CFR 493.1291(c)(1) = "For positive patient identification, either the patient's name and identification number, or a unique patient identifier and identification number." (https://www.ecfr.gov/current/title-42/part-493/section-493.1291#p-493.1291(c)(1)) and in §493.1241(c)(2) = "The patient's name or unique patient identifier." (https://www.ecfr.gov/current/title-42/part-493/section-493.1241#p-493.1241(c)(2))
APHL also recommends to include the assigning authority with ANY identifier data element (in all HL7 products this is part of the various supported identifier type data type). Thus we propose to update the definition to: "Alphanumeric value that should uniquely identify the patient over time - at minimum within one organization, ideally at the national level), including a means to identify the organization or system that assigned it."
If ONC wants to support generic identifiers, then the elements should also include the identifier type Patient Identifier Type (https://www.healthit.gov/isp/taxonomy/term/3661/level-2), to be able to differentiate what is being shared.
Submitted by BLampkins_CSTE on
CSTE Comment - v6
CSTE supports inclusion of this data element in USCDI V6. Please see previously submitted CSTE comments for additional recommendations.