Submitted by nedragarrett_CDC on
CDC's Consolidated Comment for USCDI v4
CDC continues to recommend inclusion of this high priority data element in USCDI v4
CSTE Comment:
- CSTE agrees with CDC and continues to strongly recommends that Vaccine Administration Date and Vaccination Event Record Type be included in USCDI v4. Both elements are required for immunization exchange and always have been. Each year, IIS respond to CDC’s annual report (IISAR). At the end of calendar year 2019, IIS records contained vaccine administration date 99.9% of the time with only 1 IIS reporting less than 100%. With these lacking from USCDI v4 it would be possible to list only the immunization code a patient received, but not the date the patient received the dose or if the vaccination event originated in the source system. Vaccine Administration Date enables accurate record evaluation (e.g., were doses given at the proper age and at a proper interval) while Vaccination Event Record Type enable accurate inventory decrementing by public health and aids in vaccine matching/deduplication.
Submitted by Svellanky on
CMS-CCSQ Support for Vaccination Event Record Type: USCDI v4
The immunization data element provides critical information about whether a vaccination has ever been administered, planned or reported. The current immunization data element is insufficient to identify whether the vaccination is based on the historical record or was administered at the facility submitting the vaccine. By adding vaccine event record type for immunizations, ONC can also ensure data elements necessary to determine whether vaccinations are current, and whether any vaccinations need to be administered. Vaccine efficacy analyses use this information to determine immunization population coverage. Statistical analyses help to identify underserved populations so that resources are redirected appropriately and used efficiently. This should not add any substantial burden on vendors or implementers, as this metadata should already be routinely captured. As this information helps improve accuracy of vaccine reporting, it can benefit many existing CMS vaccination quality measures.
Maturity: This data element is classified as Level 2 by ONC and continues to have strong standardization and be in wide use.
Current uses, exchange, and use cases: The vaccination event record type data element provides information that is currently lacking in the USCDI on timing of the immunizations that can improve accuracy of measurement. Immunization information may not directly provide disparity information, but it is needed together with other disparity-related data (e.g., race, ethnicity, location) to identify vaccine breakthroughs or problems with vaccination access/coverage which may also speak to broader health disparities related to general access to medical care and services. This data is particularly important for COVID-19 reporting. This data element also allows CDC to see where immunizations may be lacking and can support future CMS quality measure reporting.