Patient Demographics/Information

CDC's comment for proposed inclusion in USCDI v7

National Hospital Care Surveys (NHCS) and National Ambulatory Medical Care Survey (NAMCS) both conduct data linkages to other datasets (e.g. National Death Index, the U.S. Department of Housing and Urban Development, etc.) and publish them as restricted use data files. This data element will increase the ability to track unique patients, improving accuracy and quality in these produced datasets.

Location of data element in the current HCS CDA IG V1.2: x-path /ClinicalDocument/recordTarget/patientRole/patient/id)

This data element is in C-CDA 4.0. Link in the C-CDA IG- https://hl7.org/cda/us/ccda/StructureDefinition-USRealmHeader.html

Description of what DHCS currently receives in production: The majority of EHR files submitted for NAMCS and NHCS have identifier data for Social Security Number (SSN), patient name (first, middle, and last), date of birth, and patient address. All EHR files submitted to NHCS lack medical record number (MRN) and Health Insurance Claims Number (HIC). In addition, NHCS would like to expand the availability of identifiers to include patient control number (PCN).

National Center for Immunization and Respiratory Diseases (NCIRD) propose the inclusion of "Identifier" as a standardized data element in USCDI v7 due to its critical role in enhancing immunization efforts. As a unique identifier, it ensures that vaccination records are accurately matched to individual patients, which is essential for effective immunization programs.
Standardizing the Identifier significantly enhances the ability of public health authorities to monitor immunization coverage, assess vaccine effectiveness, and identify populations that are under-vaccinated. This capability is particularly important for coordinating responses to vaccine-preventable disease outbreaks and managing mass vaccination campaigns during public health emergencies, such as pandemics.
Furthermore, precise patient matching enabled by a consistent Identifier helps prevent duplicate immunization records, ensuring that individuals receive vaccines according to recommended schedules. This is vital for maintaining accurate immunization histories, which are crucial for effective patient care and public health reporting.
The inclusion of the Identifier also facilitates accurate reporting to Immunization Information Systems (IIS), supporting real-time public health decision-making and resource allocation. By ensuring that vaccination data is consistently linked to the correct patient, health authorities can make informed decisions about vaccine distribution and outreach efforts.
Moreover, a standardized Identifier can improve communication and coordination among healthcare providers involved in immunization efforts. It allows for seamless sharing of vaccination records, ensuring that all providers have access to the most current and accurate patient information, which is essential for effective immunization strategies.
The Identifier can also empower patients by enabling easier access to their vaccination records, fostering greater engagement in their own care and encouraging adherence to vaccination schedules. When patients can easily verify their immunization status, they are more likely to seek necessary vaccinations and participate in public health initiatives.
Incorporating the Identifier into health information technology systems will enhance data analytics capabilities, allowing for more effective tracking of vaccination trends and outcomes. This can inform public health strategies and improve the overall quality of immunization services provided to patients.
We strongly advocate for the inclusion of the "Identifier" in USCDI v7, as it promises to significantly improve the accuracy of patient identification for immunizations. Its adoption will enhance public health surveillance capabilities and ensure the successful implementation of national immunization strategies, ultimately leading to better health outcomes for the population.

CDC's Comment for draft USCDI v6

CDC is requesting that Identifier added for consideration to USCDI V6 to inform hospital and ambulatory medical care survey data collection efforts. 

Justification:  National Healthcare Surveys and NAMCS both conduct data linkages to other datasets (e.g. National Death Index, the U.S. Department of Housing and Urban Development, etc.) and publish them as restricted use data files. This data element will increase the ability to track unique patients, improving accuracy and quality in these produced datasets.

CSTE Comment - v6

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

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. 

CSTE Comment - v5

CSTE recommends renaming this data element to Patient Identifier. Also, it is very important to include 2 other data elements to provide data critical to supporting the usability of the patient identifier data element. These include the Type of Patient Identifier (which would detail whether the identifier is, for example, a medical record number, a Medicare number, a social security number, a laboratory patient identifier) and the Patient Identifier Assigning Authority (which would provide information on which organization has assigned the identifier - for example, which health care organization, which governmental agency etc.).

1. The patient identifier field is incredibly helpful for person matching and deduplication which currently requires a huge amount of manual effort at STLT public health agencies to manage the many potential duplicates across and within data streams (even with the best algorithms and automation for patient deduplication, often health department staff spend countless hours deduplicating partially matched patient records).
2. It is critical for identifying patients for follow-up - as in when medical information is sought as part of a case investigation or when additional demographics or contact information are needed in order to quickly reach a patient, or when lab results are needed from a hospital.
3. For any type of automated or semi-automated query of an HIE or another clinical repository (as will hopefully be possible through TEFCA), MR number will be invaluable in narrowing the query and ensuring the returned results pertain to the correct individual - this will save an enormous amount of time and frustration
4. For any bidirectional data exchange it would be invaluable to the receiving health care org to be able to use medical record to route the data to the correct medical record.

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's Consolidated Comment for USCDI v5

• CDC continues to recommend this data element for USCDI v5.
• NACCHO Comment: LHDs will also be able to use this to attribute encounter level information to a person-level, which is what is used for prevention analysis and program creation.

CDC's comment on behalf of CSTE for USCDI v4

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

CDC's Consolidated Comment for USCDI v4

CDC continues to recommend inclusion of this high priority data element in USCDI v4

Unified Comment from CDC

• General Comment: This comment supports the promotion of the Data Class Patient Demographics - Data Element Identifier to USCDI V3 as well as the additional Data Element of Identifier System, including the allowance of multiple instances of Identifier/ Identifier System pairs per patient (approach 1). We believe that this will allow needed flexibility to accommodate use and exchange of the variety of patient identifiers in current use in the US. An example of this approaches is: Identifier: 333224444, Identifier System: http://hl7.org/fhir/sid/us-ssn.
   
• If ONC does not choose to incorporate approach 1, (Identifier + Identifier System), in USCDI V3, we recommend allowing for the following Patient Demographic Data Class Data Elements in USCDI V3: Medicare Patient Identifier, Medical Record Number and Social Security Number. (approach 2) We believe that allowing for both approaches would be confusing, so we recommend choosing one or the other.