An instrument, machine, appliance, implant, software or other article intended to be used for a medical purpose.

Data Element
UDI-Device Identifier or UDI-DI
Description

The DI portion of the UDI placed on the lowest package level of a device that is required to meet UDI label requirements. If the device is not packaged, the UDI may be on the device itself, thereby satisfying both the UDI label and the direct mark (DM) requirement if the UDI is intended to be permanent. The primary DI is the main (primary) lookup for a medical device and meets the requirements to uniquely identify a device through its distribution and use. Taken from FDA Data Elements Reference Table - see https://www.fda.gov/media/88408/download
Submitted By: Terrie Reed / Symmetric Health Solutions
Data Element Information
Data Element Description The DI portion of the UDI placed on the lowest package level of a device that is required to meet UDI label requirements. If the device is not packaged, the UDI may be on the device itself, thereby satisfying both the UDI label and the direct mark (DM) requirement if the UDI is intended to be permanent. The primary DI is the main (primary) lookup for a medical device and meets the requirements to uniquely identify a device through its distribution and use. Taken from FDA Data Elements Reference Table - see https://www.fda.gov/media/88408/download
Rationale for Separate Consideration The UDI is a string of characters with no meaning. The UDI is composed of separate meaningful parts that should be parsed from the UDI and stored separately in a patient’s health record because each contribute to the identify of a regulated medical device. The UDI may be stored as a string to verify the human readable interpretation of the machine readable format of UDI on a device label. However, the UDI-DI and each part of the UDI-PI should also be stored in separate fields. The UDI-DI is the main (primary) lookup for a medical device and meets the requirements to uniquely identify a device through its distribution and use.
Use Case Description(s)
Use Case Description Referring to the UDI in USCDI without specifying the separate parts of the UDI has introduced unnecessary confusion for device users that are scanning the UDI. The use of UDI as a full string for documenting UDI is only necessary for data validation, not to add meaning for tracking a device and associating that device with a patient. The UDI-DI and each part of the UDI-PI (lot, serial, expiration date, manufacturing date, and donation identification number) are the values that should be stored and exchanged separately in Health IT systems. The UDI-DI is used as a field in adverse event reporting, recalls, claims, materials management and inventory control to track the device at the model version level. These use cases are currently being documented in the HL7 UDI Implementation Guidance Requirements document. The document was first balloted in September 2020 and is expected to be published by the end of the year.
Estimate the breadth of applicability of the use case(s) for this data element Every stakeholder that would capture access, use or exchange the UDI would more appropriately capture, access, use or exchange the UDI-DI and parts of the UDI-PI.
Link to use case project page https://www.hl7.org/special/Committees/projman/searchableProjectIndex.cfm?action=edit&ProjectNumber=1238
Use Case Description Links to additional use cases
UDI: A Roadmap for Effective Implementation by The Brookings Institute https://www.fda.gov/media/91988/download
Implementing Unique Device Identification: Recommendations for Integrating Medical Device Data Throughout the Health Care System by The Pew Charitable Trust https://www.pewtrusts.org/-/media/assets/2015/09/udiimplementation-report.pdf
MDEpINET Building UDI into Longitudinal Data for Device Evaluation Final Summary Report and Roadmap http://mdepinet.org/wp-content/uploads/BUILD-Update.pdf
Estimate the breadth of applicability of the use case(s) for this data element It is estimated that approximately 200 million people would use, be exposed to or derive better data to make decisions about implantable devices after the UDI were separated into discrete fields. This estimate is based upon the following approximations and assumptions that would also be be more accurate if the UDI were split into UDI-DI and UDI-PI and all of this data were available in health records.
Approximately 12 million implant procedures performed in the US per year.
An average implant life of 10 years
100 million people in the US with at least one implant – 20% estimated to have multiple implants – this is equivalent to 1/3 of US population over 50 years old
Average US household of 2-3 people with estimate that at least one other person besides the person with the implant cares about the implant
Approximation - 200 million people would benefit from having UDI or know someone they care about with an implanted device and would benefit from the information.
Healthcare Aims
  • Improving patient experience of care (quality and/or satisfaction)
  • Improving the health of populations
  • Reducing the cost of care
  • Improving provider experience of care
Maturity of Use and Technical Specifications for Data Element
Applicable Standard(s) Please see FDA UDI regulation and FDA Data Elements Reference Table - see
https://www.fda.gov/media/88408/download.
Please see FDA Formats by Accredited Issuing Agency that shows the structured of each of the parts of the UDI as a complete standard - https://www.fda.gov/media/96648/download
UDI-DI and all AccessGUDID data elements are listed in NCI Thesaurus. See https://www.nlm.nih.gov/research/umls/sourcereleasedocs/current/NCI_FDA/index.html#:~:text=%20The%20NCI%20Thesaurus%20includes%20the%20following%20FDA,Global%20Unique%20Device%20Identification%20Database%20%28GUDID%29%20More%20
https://www.fda.gov/media/96648/download
Additional Specifications HL7 Cross Paradigm Implementation Guide: UDI Pattern, Release 2 (Normative)
Women's Health Technologies (WHT) Coordinated Registry Network (CRN) FHIR Implementation Guide (STU)
HL7 CDA® R2 IG: C-CDA Templates for Clinical Notes R2.1 Companion Guide, Release 2 - US Realm (STU)
Current Use In limited use in production environments
Extent of exchange 2-3
Potential Challenges
Restrictions on Standardization (e.g. proprietary code) The UDI-DI and UDI-PI currently exist in human and machine readable format on the label of devices. The UDI-DI are publicly available in AccessGUDID. There are no restriction on the use of this data.
Restrictions on Use (e.g. licensing, user fees) No restrictions
Privacy and Security Concerns The UDI-DI can be part of a limited or de-identified data set. See https://www.hhs.gov/hipaa/for-professionals/faq/2071/can-device-identifier-di-portion-unique-device-identifier-udi-be-part-limited-or-de-identified/index.html
The fact that UDI-DI must be separate from the remainder of the UDI to qualify as a limited data set provides more rationale for UDI-DI to be stored separately in HIT.
Estimate of Overall Burden To effectively implement UDI in healthcare a system should be storing each of the UDI parts separately. If the system is not, it is adding unecessary burden to the UDI adoption process.

Comment

Submitted by melanie.kourba… on

APHL recommends that ASTP provide more guidance on what devices should be tracked as non-implantables; this guidance would be useful for health IT developers to know what within the laboratory setting should be tracking a UDI. For the laboratory we suggest ASTP focus on the instrument (Instrument Unique Identifier) and testkit (Test Kit Unique Identifier) which would be covered by this expansion. Identifiers for instrument and testkit will allow better tracking, accountability, and interpretation of laboratory results, resulting in higher quality data and more reliable analyses.

Most useful would be the tracking at the model level (not the serial number), though tracking the full UDI of the device (not its packaging) will include the device identifier aspect and may be easier when the data can be acquired by scanning the product barcode. Currently many data producers are not capable of storing and exchanging this data element; capturing this data in source systems and near-source intermediaries such as instruments, LIS, RIS, PoCs automatically and being able to include them into downstream communications is required before it can be required in EHR certification. APHL notes that all HL7 products can accommodate the exchange of device information including the full UDI, as well as parts of the UDI like the device Identifier, and IHE LAW supports “manufacturer” and “model” as well as the serial number for the transactions between instruments and analyzer managers. Thus, once the issue of capturing it at the source or source-intermediary level is resolved, the UDI information can be exchanged. 

At the same time, ASTP should take steps to ensure that EHRs are ready to accommodate UDI once the source systems have been updated. In order to fully support laboratory data exchange, the capability to track and send UDI (non-implantable) should be added as a criterion in future EHR certifications. 

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