United States Core Data for Interoperability (USCDI)
The United States Core Data for Interoperability (USCDI) is a standardized set of health data classes and constituent data elements for nationwide, interoperable health information exchange. Review the USCDI Fact Sheet to learn more.
A USCDI Data Class is an aggregation of Data Elements by a common theme or use case.
A USCDI Data Element is a piece of data defined in USCDI for access, exchange or use of electronic health information.
USCDI ONC New Data Element & Class (ONDEC) Submission System
USCDI V1
Please reference the USCDI version 1 document to the left for applicable standards versions associated with USCDI v1.
Harmful or undesired physiological responses associated with exposure to a substance.
Health professional’s conclusions and working assumptions that will guide treatment of the patient.
Information about a person who participates or is expected to participate in the care of a patient.
Narrative patient data relevant to the context identified by note types.
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- Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name.
Desired state to be achieved by a patient.
Health related matter that is of interest, importance, or worry to someone who may be the patient, patient’s family or patient’s health care provider.
Record of vaccine administration.
Analysis of clinical specimens to obtain information about the health of a patient.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Data used to categorize individuals for identification, records matching, and other purposes.
Activity performed for or on a patient as part of the provision of care.
The metadata, or extra information about data, regarding who created the data and when it was created.
Representing a patient’s smoking behavior.
Unique identifier(s) for a patient's implantable device(s).
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
USCDI V2
The USCDI v2 contains data classes and elements from USCDI v1 and new data classes and elements submitted through the ONDEC system. Please reference the USCDI Version 2 document to the left for applicable vocabulary standards versions associated with USCDI v2 and to the ONC Standards Bulletin 21-3 for more information about the process to develop USCDI v2 and future versions.
Harmful or undesired physiological responses associated with exposure to a substance.
Health professional’s conclusions and working assumptions that will guide treatment of the patient.
Information about a person who participates or is expected to participate in the care of a patient.
Narrative patient data relevant to the context identified by note types.
-
- Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name.
Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.
Tests that result in visual images requiring interpretation by a credentialed professional.
Information related to interactions between healthcare providers and a patient.
Desired state to be achieved by a patient.
Health related matter that is of interest, importance, or worry to someone who may be the patient, patient’s family or patient’s health care provider.
Record of vaccine administration.
Analysis of clinical specimens to obtain information about the health of a patient.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Data used to categorize individuals for identification, records matching, and other purposes.
Condition, diagnosis, or reason for seeking medical attention.
Activity performed for or on a patient as part of the provision of care.
The metadata, or extra information about data, regarding who created the data and when it was created.
Representing a patient’s smoking behavior.
Unique identifier(s) for a patient's implantable device(s).
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
USCDI V3
USCDI v3 contains data classes and elements from USCDI v2 and new data classes and elements submitted through the ONDEC system. Please reference the USCDI Version 3 document to the left for applicable vocabulary standards versions associated with USCDI v3 and to the ONC Standards Bulletin 22-2 for more information about the process to develop USCDI v3 and future versions.
Harmful or undesired physiological responses associated with exposure to a substance.
Health professional’s conclusions and working assumptions that will guide treatment of the patient.
Information about a person who participates or is expected to participate in the care of a patient.
Narrative patient data relevant to the context identified by note types.
-
- Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name.
Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.
Tests that result in visual images requiring interpretation by a credentialed professional.
Information related to interactions between healthcare providers and a patient.
Desired state to be achieved by a patient.
Data related to an individual’s insurance coverage for health care.
Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.
Record of vaccine administration.
Analysis of clinical specimens to obtain information about the health of a patient.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Data used to categorize individuals for identification, records matching, and other purposes.
Condition, diagnosis, or reason for seeking medical attention.
Activity performed for or on a patient as part of the provision of care.
The metadata, or extra information about data, regarding who created the data and when it was created.
Unique identifier(s) for a patient's implantable device(s).
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
USCDI V4
USCDI v4 added 20 data elements and one data class to USCDI v3. Please reference the USCDI v4 standard document and the ONC Standards Bulletin 23-2 for details. To review the prioritization criteria ONC used to select the USCDI v4 data elements, refer to the ONC Standards Bulletin 22-2.
Harmful or undesired physiological responses associated with exposure to a substance.
Information about a person who participates or is expected to participate in the care of a patient.
Narrative patient data relevant to the context identified by note types.
-
- Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name.
Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.
Tests that result in visual images requiring interpretation by a credentialed professional.
Information related to interactions between healthcare providers and a patient.
Physical place of available services or resources.
Desired state to be achieved by a person or a person’s elections to guide care.
Data related to an individual’s insurance coverage for health care.
Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.
Record of vaccine administration.
Analysis of clinical specimens to obtain information about the health of a patient.
An instrument, machine, appliance, implant, software or other article intended to be used for a medical purpose.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Data used to categorize individuals for identification, records matching, and other purposes.
Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.
Condition, diagnosis, or reason for seeking medical attention.
Activity performed for or on a patient as part of the provision of care.
The metadata, or extra information about data, regarding who created the data and when it was created.
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
USCDI V5
USCDI v5 was published on July 16, 2024, and includes 16 new data elements and two new data classes. Please read the USCDI v5 standard document and the ONC Standards Bulletin 24-2 for details.
Harmful or undesired physiological responses associated with exposure to a substance.
Information about a person who participates or is expected to participate in the care of a patient.
Narrative patient data relevant to the context identified by note types.
-
- Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name.
Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.
Tests that result in visual images requiring interpretation by a credentialed professional.
Information related to interactions between healthcare providers and a patient.
Physical place of available services or resources.
Desired state to be achieved by a person or a person’s elections to guide care.
Data related to an individual’s insurance coverage for health care.
Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.
Record of vaccine administration.
Analysis of clinical specimens to obtain information about the health of a patient.
An instrument, machine, appliance, implant, software or other article intended to be used for a medical purpose.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Findings or other clinical data collected about a patient during care.
Provider-authored request for the delivery of patient care services.
Data used to categorize individuals for identification, records matching, and other purposes.
Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.
Condition, diagnosis, or reason for seeking medical attention.
Activity performed for or on a patient as part of the provision of care.
The metadata, or extra information about data, regarding who created the data and when it was created.
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
Draft USCDI V6
ASTP/ONC published Draft USCDI v6 on January 14, 2025, and proposes to add 6 new data elements. Please read the Draft USCDI v6 standard document and the ASTP Standards Bulletin 25-1 for details. ASTP/ONC is accepting comments here through May 12, 2025, at 11:59 PM ET.
Harmful or undesired physiological responses associated with exposure to a substance.
Information about a person who participates or is expected to participate in the care of a patient.
Narrative patient data relevant to the context identified by note types.
-
- Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name.
Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.
Tests that result in visual images requiring interpretation by a credentialed professional.
Information related to interactions between healthcare providers and a patient.
Physical place of available services or resources.
Desired state to be achieved by a person or a person’s elections to guide care.
Data related to an individual’s insurance coverage for health care.
Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.
Record of vaccine administration.
Analysis of clinical specimens to obtain information about the health of a patient.
An instrument, machine, appliance, implant, software or other article intended to be used for a medical purpose.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Findings or other clinical data collected about a patient during care.
Provider-authored request for the delivery of patient care services.
Data used to categorize individuals for identification, records matching, and other purposes.
Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.
Condition, diagnosis, or reason for seeking medical attention.
Activity performed for or on a patient as part of the provision of care.
The metadata, or extra information about data, regarding who created the data and when it was created.
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
- Represented by a terminology standard or SDO-balloted technical specification or implementation guide.
- Data element is captured, stored, or accessed in multiple production EHRs or other HIT modules from more than one developer.
- Data element is electronically exchanged between more than two production EHRs or other HIT modules of different developers using available interoperability standards.
- Use cases apply to most care settings or specialties.
Level 2
Harmful or undesired physiological responses associated with exposure to a substance.
Material substance originating from a biological entity intended to be transplanted or infused into another (possibly the same) biological entity.
Tests that result in visual images requiring interpretation by a credentialed professional.
Physical place of available services or resources.
Data related to an individual’s insurance coverage for health care.
Record of vaccine administration.
An instrument, machine, appliance, implant, software or other article intended to be used for a medical purpose.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Provider-authored request for the delivery of patient care services.
Data used to categorize individuals for identification, records matching, and other purposes.
Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.
Condition, diagnosis, or reason for seeking medical attention.
Activity performed for or on a patient as part of the provision of care.
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
- Represented by a terminology standard or SDO-balloted technical specification or implementation guide.
- Data element is captured, stored, or accessed in at least one production EHR or HIT module.
- Data element is electronically exchanged between two production EHRs or other HIT modules using available interoperability standards.
- Use cases apply to several care settings or specialties.
Level 1
Material substance originating from a biological entity intended to be transplanted or infused into another (possibly the same) biological entity.
Narrative patient data relevant to the context identified by note types.
-
- Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name.
Physical place of available services or resources.
Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.
Analysis of clinical specimens to obtain information about the health of a patient.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Data used to categorize individuals for identification, records matching, and other purposes.
The metadata, or extra information about data, regarding who created the data and when it was created.
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
- Not represented by a terminology standard or SDO-balloted technical specification or implementation guide.
- Data element is captured, stored, or accessed in limited settings such as a pilot or proof of concept demonstration.
- Data element is electronically exchanged in limited environments, such as connectathons or pilots.
- Use cases apply to a limited number of care settings or specialties, or data element represents a specialization of other, more general data elements.
Level 0
Harmful or undesired physiological responses associated with exposure to a substance.
Material substance originating from a biological entity intended to be transplanted or infused into another (possibly the same) biological entity.
Information about a person who participates or is expected to participate in the care of a patient.
Narrative patient data relevant to the context identified by note types.
-
- Usage note: Clinical Notes data elements are content exchange standard agnostic. They should not be interpreted or associated with the structured document templates that may share the same name.
Non-imaging and non-laboratory tests performed that result in structured or unstructured findings specific to the patient to facilitate the diagnosis and management of conditions.
Tests that result in visual images requiring interpretation by a credentialed professional.
Information related to interactions between healthcare providers and a patient.
Health data as reflected in a patient's Explanation of Benefits (EOB) statements, typically derived from claims and other administrative data.
Desired state to be achieved by a patient.
Desired state to be achieved by a person or a person’s elections to guide care.
Data related to an individual’s insurance coverage for health care.
Assessments of a health-related matter of interest, importance, or worry to a patient, patient’s family, or patient’s healthcare provider that could identify a need, problem, or condition.
Record of vaccine administration.
Analysis of clinical specimens to obtain information about the health of a patient.
An instrument, machine, appliance, implant, software or other article intended to be used for a medical purpose.
Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.
Findings or other clinical data collected about a patient during care.
Provider-authored request for the delivery of patient care services.
Data used to categorize individuals for identification, records matching, and other purposes.
Conclusions and working assumptions that will guide treatment of the patient, and recommendations for future treatment.
Condition, diagnosis, or reason for seeking medical attention.
Activity performed for or on a patient as part of the provision of care.
The metadata, or extra information about data, regarding who created the data and when it was created.
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
The USCDI ONC New Data Element and Class (ONDEC) Submission System supports a predictable, transparent, and collaborative process, allowing health IT stakeholders to submit new data elements and classes for future versions of USCDI. Click here for more information and to submit new data elements.
The USCDI standard will follow the Standards Version Advancement Process described in the Cures rule to allow health IT developers to update their systems to newer version of USCDI and provide these updates to their customers.
Comment
Submitted by markaroberts85 on
CARIN Alliance Comments on USCDI V6
The CARIN Alliance thanks you for the opportunity to provide feedback on USCDI version 6. The CARIN Alliance is a multi-sector group of stakeholders representing numerous hospitals, thousands of physicians, and millions of consumers and caregivers. We are committed to promoting the ability for consumers and their authorized caregivers to gain digital access to their health information via the open APIs and the ability to use that information in any third-party application they choose.
The CARIN Alliance has consistently advocated for the inclusion of the data from the Common Payer Consumer Data Set (CPCDS), which is core to the FHIR®-based CARIN IG for Blue Button®, to be included in USCDI versions 2, 3, 4, and 5. These elements, which are not all included in USCDI, are essential to advancing the ASTP/ONC’s mission of establishing “a standardized set of health data classes and constituent data elements for nationwide, interoperable health information exchange.”
Please find our comments attached.
Submitted by Allina Health … on
Allina Health Comments USCDI v6
Dear Mr. Posnack,
Allina Health welcomes the opportunity to submit comments on draft v6 of the USCDI. Please see the attached document for the entirety of our comments.
Submitted by ravi.kafle@doh… on
Washington State Department of Health comments - USCDI v6 Draft
Dear Mr. Posnack,
The following comments are being submitted on behalf of the Washington State Department of Health for consideration by you and the draft USCDI version 6 review committee:
Inclusion of ‘Unique Device Identifier’ data element:
Washington DOH strongly supports the inclusion of Unique Device Identifier (UDI) as the data element in ‘Medical Devices’ class. The Department of Health in Washington State as well as other health departments in the nation, together with the hospitals, would use identifiers of the equipment and supplies that gets used by the patients. For the public health domain, this data is specifically important from the perspective of public health emergency preparedness and response. This element is also important for assessment and keeping track of the devices and supplies that the health facilities require.
Standardization of symptoms in ‘History and Physical’ data element in the ‘Clinical Notes’ class:
‘Clinical Notes’ class has data element named ‘History and Physical’. The patient’s history is free text note typed in by the provider. The clinical notes needs to be modeled to a standardized set of symptoms. This is being explored by HL7 international for modeling by relevant workgroups. USCDI also needs to include the standardized symptoms in the ‘History and Physical’ data class.
Advance Directive:
The Draft version 6 has ‘Advance Directive Observation’ as a new data element in the Class ‘Observation’. At the same time, however, Advance Directive also exists as a Class in Level 1. It is recommended that the Data Class be moved from Level 1 to Final USCDI version 6. The classification of Advance Directive under observation may be revisited.
Portable Medical Orders:
Washington DOH strongly supports the inclusion of Portable Medical Orders (PMO) as the data element in ‘Medical Orders’ class. The DOH, with the authority for a living will registry supports patient being able to express their wishes, hence, empowering individual patients.
With best regards,
Ravi Kafle
Senior Architect - Interoperability/Informatics | Senior Epidemiologist
Washington State Department of Health
Submitted by marciantemark on
The Digital Quality…
The Digital Quality Implementers Community (DQIC) appreciates this opportunity to review and provide feedback on ASTP/ONC’s United States Core Data for Interoperability Version 6 (USCDI).
Please see our consensus-based response regarding both proposed changes as well as suggestions for future considerations in the attached comment letter.
Submitted by msaito on
Epic's Comments on Draft USCDI v6
Please see the attached feedback on the Draft USCDI v6.
Submitted by AMIA_Policy on
AMIA Comments on USCDI v6 Draft
On behalf of the American Medical Informatics Association (AMIA), we appreciate the opportunity to comment on USCDI v6. Please find our comments attached.
Submitted by mbkurilo@immre… on
IIS Community Comments on USCDI V6
May 12, 2025
RE: USCDI Version 6
Dear Mr. Posnack -
On behalf of the American Immunization Registry Association (AIRA) we are pleased to submit comments on the Assistant Secretary for Technology and Policy, Office of the National Coordinator’s (ASTP/ONC’s) recently released documents related to United States Core Data for Interoperability, version 6. These comments are a compilation of the input of our members which include over 100 organizations representing Public Health Immunization Information Systems (IIS), IIS implementers and vendors, non-profit organizations and partners. IIS interface with a broad range of stakeholders, including providers, pharmacists, schools, child care facilities, health plans and payers, among others.
IIS and our partners are, quite obviously, very invested in promoting smooth interoperability to ensure broad data use. At the point of clinical care, an IIS provides consolidated immunization records and forecasts to support clinical decisions. At the population level, an IIS provides aggregate data and information on vaccinations for surveillance, program operations and public health action. It is critical that the role of Public Health is recognized as a key part of health IT strategy moving forward.
To that end, we have specific input on those data elements selected for inclusion in ONC’s USCDI Version 6, and those not currently included.
AIRA provides suggestions on the ASTP/ONC draft USCDI Version 6 in our comments presented on attached document, organized by the specific questions asked by ASTP/ONC in the draft USCDI version 6. Please feel free to contact me with any questions: mbkurilo@immregistries.org.
We greatly appreciate the opportunity to comment on these resources, and we look forward to continuing to collaborate to ensure high-value health IT interoperability with our many partners.
Sincerely,
Mary Beth Kurilo, MPH, MSW
Senior Director of Health Informatics
Submitted by Areinert on
ADVION Advocates comments on Draft USCDI v6
May 12, 2025
Acting Assistant Secretary Steve Posnack, MS, MHS
Assistant Secretary for Technology Policy and Office of the National Coordinator for Health Information Technology (ASTP/ONC)
U.S. Department of Health and Human Services
330 C Street SW, 7th Floor
Washington, DC 20201
Submitted Electronically Via HealthIT.gov
RE: United States Core Data for Interoperability Draft Version 6
Dear Mr. Posnack:
ADVION is writing to provide public comment on the Draft United States Core Data for Interoperability (USCDI) Version 6, particularly regarding its implications for long-term post-acute care providers, health information technology vendors that serve post-acute care providers and rehabilitation specialists.
ADVION is a trade association representing the providers of ancillary care and services for the long-term and post-acute care (LTPAC) sector. Our members include rehabilitation therapy companies; providers of clinical laboratory and portable x-ray services; suppliers of complex medical equipment and other specialized supplies; and health information technology (health IT) vendors that develop and distribute full clinical electronic health records (EHRs), billing and point-of-care health IT systems and other software solutions serving the majority of LTPAC providers (i.e., assisted living facilities, Home Health Agencies (HHAs), Inpatient Rehabilitation Facilities (IRFs), Long Term Care Hospitals (LTCHs) and Skilled Nursing Facilities (SNFs)). ADVION is a founding member of the Long Term & Post-Acute Care Health IT Collaborative, which was formed in 2005 to advance health IT issues by encouraging coordination among provider organizations, policymakers, vendors, payers and other stakeholders.
For providers and vendors in the long-term care sector, the integration of standardized data elements is crucial to enhancing interoperability and improving patient outcomes. The proposed additions in USCDI Version 6, such as the inclusion of Facility Information and Unique Device Identifier, are significant to LTPAC providers. These new data elements will facilitate better tracking of patient care across various settings and improve communication among care providers, thereby streamlining transitions of care for our patients.
However, the requirement to code and implement these new data elements into our Electronic Health Records (EHRs) presents substantial challenges to LTPAC vendors and providers. LTPAC providers will need to allocate resources to update their EHR systems, ensuring that the systems can accurately capture and report the new standards. This may involve not only technical adjustments but also comprehensive training for staff to familiarize them with the new coding requirements and data entry processes.
In particular, the inclusion of the Unique Device Identifier (UDI) poses usability and workflow integration challenges. Nursing home and SNF teams do not routinely capture UDIs at the bedside, and current EHR interfaces may not support structured entry, scanning, or FHIR-based exchange of device information. Vendors would benefit from implementation guidance regarding device types most relevant to LTPAC and appropriate timing of UDI capture during transitions of care.
The Portable Medical Orders element (e.g., POLST, MOLST) is highly relevant to LTPAC but varies significantly across states. LTPAC vendors will need guidance on how to consistently support interoperable exchange of portable medical orders in both structured and scanned formats. Furthermore, integration into workflow, especially when forms are received externally, must account for role-based documentation practices that often differ from hospital settings.
While we support the emphasis on standardized Patient Summary and Care Plan elements, it is important to recognize that existing regulatory assessments such as Minimum Data Set (MDS 3.0), required by Medicare for residents of skilled nursing facilities, already include many of these data points. If not aligned, these new requirements may introduce documentation duplication or conflict with federally mandated formats.
From the perspective of an IT vendor, most LTPAC EHRs are not ONC-certified, as they are not currently subject to federal certification mandates. As such, any interoperability expectations stemming from USCDI must account for the technical and financial limitations of these systems. One possible approach could be to establish a pathway for modular compliance or offer certification incentives, which may help vendors gradually align with ONC goals without requiring complete system overhauls.
We also note that the proposed new Social Determinants of Health (SDOH) and cognitive/functional assessment elements overlap with MDS and therapy evaluations. Ensuring that these can be mapped and reused, rather than manually re-entered, will be critical for workflow efficiency. There is also a need for education and standardization of coding practices, as LTPAC staff may not be accustomed to using LOINC or SNOMED for daily clinical documentation.
Finally, consistent with our prior concerns, we reiterate the risk associated with the removal of pronouns, sexual orientation, and gender identity (SOGI) as noted on page 4 of the draft USCDI v6. These elements are critical for providing respectful, person-centered care in the LTPAC setting, particularly for vulnerable LGBTQ+ populations. Their removal could lead to the loss of essential identity-related information that enables inclusive care and helps reduce disparities. From an IT perspective, LTPAC vendors who have already built support for these elements may face uncertainty and additional costs to reconfigure systems or rely on custom, non-standard data fields. This creates challenges for interoperability and consistent data exchange across care settings. Moreover, the absence of these standardized fields impedes efforts to track and address equity in care delivery. The implementation burden of new standards, especially when paired with the removal of valuable identity data, highlights the need for consistent guidance, flexibility, and support across the LTPAC sector.
We must also highlight the potential implementation burden associated with these new data requirements. Ensuring that providers are supported through adequate funding and resources is essential to implementing these new standards effectively.
We urge you to consider the unique challenges faced by LTPAC providers, vendors and rehabilitation specialists as you finalize the USCDI v6. The successful implementation of these data standards offers the potential to enhance patient care significantly, but it must be accompanied by thoughtful consideration of the resources and training required for effective adoption.
Thank you for the opportunity to provide input on this important matter. I am available to provide additional input or clarification and can be reached at 202 803-2385 or Cynthia@ADVIONadvocates.org.
Sincerely,
Cynthia K. Morton, MPA
Chief Executive Officer
Submitted by Areinert on
ADVION Advocates comments on Draft USCDI v6
May 12, 2025
Acting Assistant Secretary Steve Posnack, MS, MHS
Assistant Secretary for Technology Policy and Office of the National Coordinator for Health Information Technology (ASTP/ONC)
U.S. Department of Health and Human Services
330 C Street SW, 7th Floor
Washington, DC 20201
Submitted Electronically Via HealthIT.gov
RE: United States Core Data for Interoperability Draft Version 6
Dear Mr. Posnack:
ADVION is writing to provide public comment on the Draft United States Core Data for Interoperability (USCDI) Version 6, particularly regarding its implications for long-term post-acute care providers, health information technology vendors that serve post-acute care providers and rehabilitation specialists.
ADVION is a trade association representing the providers of ancillary care and services for the long-term and post-acute care (LTPAC) sector. Our members include rehabilitation therapy companies; providers of clinical laboratory and portable x-ray services; suppliers of complex medical equipment and other specialized supplies; and health information technology (health IT) vendors that develop and distribute full clinical electronic health records (EHRs), billing and point-of-care health IT systems and other software solutions serving the majority of LTPAC providers (i.e., assisted living facilities, Home Health Agencies (HHAs), Inpatient Rehabilitation Facilities (IRFs), Long Term Care Hospitals (LTCHs) and Skilled Nursing Facilities (SNFs)). ADVION is a founding member of the Long Term & Post-Acute Care Health IT Collaborative, which was formed in 2005 to advance health IT issues by encouraging coordination among provider organizations, policymakers, vendors, payers and other stakeholders.
For providers and vendors in the long-term care sector, the integration of standardized data elements is crucial to enhancing interoperability and improving patient outcomes. The proposed additions in USCDI Version 6, such as the inclusion of Facility Information and Unique Device Identifier, are significant to LTPAC providers. These new data elements will facilitate better tracking of patient care across various settings and improve communication among care providers, thereby streamlining transitions of care for our patients.
However, the requirement to code and implement these new data elements into our Electronic Health Records (EHRs) presents substantial challenges to LTPAC vendors and providers. LTPAC providers will need to allocate resources to update their EHR systems, ensuring that the systems can accurately capture and report the new standards. This may involve not only technical adjustments but also comprehensive training for staff to familiarize them with the new coding requirements and data entry processes.
In particular, the inclusion of the Unique Device Identifier (UDI) poses usability and workflow integration challenges. Nursing home and SNF teams do not routinely capture UDIs at the bedside, and current EHR interfaces may not support structured entry, scanning, or FHIR-based exchange of device information. Vendors would benefit from implementation guidance regarding device types most relevant to LTPAC and appropriate timing of UDI capture during transitions of care.
The Portable Medical Orders element (e.g., POLST, MOLST) is highly relevant to LTPAC but varies significantly across states. LTPAC vendors will need guidance on how to consistently support interoperable exchange of portable medical orders in both structured and scanned formats. Furthermore, integration into workflow, especially when forms are received externally, must account for role-based documentation practices that often differ from hospital settings.
While we support the emphasis on standardized Patient Summary and Care Plan elements, it is important to recognize that existing regulatory assessments such as Minimum Data Set (MDS 3.0), required by Medicare for residents of skilled nursing facilities, already include many of these data points. If not aligned, these new requirements may introduce documentation duplication or conflict with federally mandated formats.
From the perspective of an IT vendor, most LTPAC EHRs are not ONC-certified, as they are not currently subject to federal certification mandates. As such, any interoperability expectations stemming from USCDI must account for the technical and financial limitations of these systems. One possible approach could be to establish a pathway for modular compliance or offer certification incentives, which may help vendors gradually align with ONC goals without requiring complete system overhauls.
We also note that the proposed new Social Determinants of Health (SDOH) and cognitive/functional assessment elements overlap with MDS and therapy evaluations. Ensuring that these can be mapped and reused, rather than manually re-entered, will be critical for workflow efficiency. There is also a need for education and standardization of coding practices, as LTPAC staff may not be accustomed to using LOINC or SNOMED for daily clinical documentation.
Finally, consistent with our prior concerns, we reiterate the risk associated with the removal of pronouns, sexual orientation, and gender identity (SOGI) as noted on page 4 of the draft USCDI v6. These elements are critical for providing respectful, person-centered care in the LTPAC setting, particularly for vulnerable LGBTQ+ populations. Their removal could lead to the loss of essential identity-related information that enables inclusive care and helps reduce disparities. From an IT perspective, LTPAC vendors who have already built support for these elements may face uncertainty and additional costs to reconfigure systems or rely on custom, non-standard data fields. This creates challenges for interoperability and consistent data exchange across care settings. Moreover, the absence of these standardized fields impedes efforts to track and address equity in care delivery. The implementation burden of new standards, especially when paired with the removal of valuable identity data, highlights the need for consistent guidance, flexibility, and support across the LTPAC sector.
We must also highlight the potential implementation burden associated with these new data requirements. Ensuring that providers are supported through adequate funding and resources is essential to implementing these new standards effectively.
We urge you to consider the unique challenges faced by LTPAC providers, vendors and rehabilitation specialists as you finalize the USCDI v6. The successful implementation of these data standards offers the potential to enhance patient care significantly, but it must be accompanied by thoughtful consideration of the resources and training required for effective adoption.
Thank you for the opportunity to provide input on this important matter. I am available to provide additional input or clarification and can be reached at 202 803-2385 or Cynthia@ADVIONadvocates.org.
Sincerely,
Cynthia K. Morton, MPA
Chief Executive Officer
Submitted by Riki Merrick on
SHIELD Community Comment on…
SHIELD Community Comment on USCDI V6 Draft:
SHIELD strongly encourages ASTP/ONC to consider expanding USCDI’s laboratory data class to more formally define a data model for the current collection of data elements, including more formal vocabulary bindings. This would add great value by improving laboratory data interoperability and could be an opportunity to onboard Laboratory Information Systems into FHIR data exchange with standardized source data. SHIELD would be excited to offer its industry, informatics and healthcare expertise to any effort to build out a shared laboratory data model with other laboratory interoperability stakeholders.
Unique Device Identifier:
HIT should support the addition of UDIs to laboratory results, the updating of UDIs (if entered in error), the association of one or more UDIs to a laboratory result, exchange of the UDI with laboratory results, receipt of all UDIs associated to laboratory results and search for UDIs and/or laboratory results reflecting both.
Laboratory Order:
Performance Time (under Procedure):
Result Unit of Measure:
SHIELD suggests use of UCUM for unit in measure unless the test has an element that is not captured through a standardized set of units (such as a clinical set of criteria specific to an individual laboratory test).
Updated vocabulary: