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.

  •  
  • 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.

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.

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.

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.

USCDI V3

Please read the USCDI v3 standard document and the ONC Standards Bulletin 22-2 for details. Consistent with EO 14168 and OPM guidance, ASTP/ONC is exercising enforcement and issuing certification guidance for the ONC Health IT Certification Program with respect to certain data elements in USCDI v3. For more information see https://www.healthit.gov/topic/uscdi-v3-data-elements-enforcement-discretion.

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.

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.

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.

USCDI V3.1

Please read the USCDI v3.1 standard document and the ONC Standards Bulletin 22-2 for details. USCDI version 3.1 updates USCDI version 3 with the following changes: consistent with Executive Order 14168, the Sex, Sexual Orientation, and Gender Identity data elements have been removed or updated in the Patient Demographics/Information Data Class.

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.

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.

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.

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.

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.

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.

Information that guides 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.

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.

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.

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.

 Usage notes: Orders convey a provider’s intent to have a service performed on or for a patient, or to give instructions on future care.

Information that guides 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.

USCDI V6

ASTP/ONC published USCDI v6 on July 24, 2025, which includes 6 new data elements. Please read the USCDI v6 Standard Document and the ASTP/ONC Standards Bulletin 25-2 for details. ASTP/ONC welcomes input on future versions during the USCDI feedback period, open through September 29, 2025, at 11:59 PM ET. During this time, ASTP/ONC is accepting new data element submissions through ONDEC, and comments on existing data elements may be entered via the updated commenting feature on the USCDI data element pages.

Harmful or undesired physiological responses associated with exposure to a substance.

Information that guides treatment of the patient and recommendations for future treatment.

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.

Family member health condition(s) that are relevant to a patient's 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.

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.

 Usage notes: Orders convey a provider’s intent to have a service performed on or for a patient, or to give instructions on future care.

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.

Level 2 data elements meet the following criteria:
  • 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.

Data related to an individual’s insurance coverage for health care.

Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.

Provider-authored request for the delivery of patient care services.

 Usage notes: Orders convey a provider’s intent to have a service performed on or for a patient, or to give instructions on future care.

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.

Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.

Level 1 data elements meet the following criteria:
  • 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.

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.

Level 0 data elements meet the following criteria:
  • 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.

Tests that result in visual images requiring interpretation by a credentialed professional.

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.

Findings or other clinical data collected about a patient during care.

Provider-authored request for the delivery of patient care services.

 Usage notes: Orders convey a provider’s intent to have a service performed on or for a patient, or to give instructions on future care.

Information that guides treatment of the patient and recommendations for future treatment.

Condition, diagnosis, or reason for seeking medical attention.

Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.

 

All USCDI Versions

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

American Clinical Laboratory Assoc. Comments on USCDI Draft V3

April 18, 2022

Micky Tripathi, PhD, MPP National Coordinator for Health Information Technology Office of the National Coordinator for Health Information Technology U.S. Department of Health and Human Services 330 C St SW, Floor 7 Washington, DC 20201

Re: United States Core Data for Interoperability (USCDI) v3 [Draft for Comment]


Dear Dr. Tripathi,

The American Clinical Laboratory Association (ACLA) is pleased to submit our comments in response to the United States Core Data for Interoperability (USCDI) v3 [Draft for Comment] (hereinafter the “Draft”). We appreciate the opportunity to comment on the Draft Version 3.

ACLA is the national trade association representing leading laboratories that deliver essential diagnostic health information to patients and providers. ACLA members are at the forefront of driving diagnostic innovation to meet the country’s evolving health care needs and provide vital clinical laboratory tests that identify and prevent infectious, acute, and chronic disease. ACLA works to advance the next generation of health care delivery through policies that expand access to lifesaving testing services.


ACLA applauds your leadership in releasing the Draft in order to further advance health information technology (HIT) interoperability, a critical and vital goal for improving the quality of care for patients. ACLA member laboratories appreciate the opportunity to comment on the Draft and hope these comments serve to continue to move interoperability forward.


We thank ONC for its consideration of our comments. Please contact me at 202-637-9466 or jkegerize@acla.com with any questions.
Sincerely,
Joan Kegerize
Vice President for Reimbursement & Scientific Affairs


ATTACHMENT: ACLA COMMENTS


The following comments are submitted by the American Clinical Laboratory Association:
Thank you for the opportunity to comment on the USCDI v3.

Proposed USCDI V3 Additions for Laboratory Data Class:
Laboratory/Specimen Type
https://www.healthit.gov/isa/taxonomy/term/2491/draft-uscdi-v3
Data Element:
Specimen Type Type of specimen (e.g., nasopharyngeal swab, whole blood, serum, urine, wound swab) on which a lab test is performed.
Original Submission:
From CDC: | Interoperability Standards Advisory (ISA) (healthit.gov)
ACLA Comment:
These comments pertain to the “Applicable Vocabulary Standard(s)” which might be named in future USCDI versions.
The original submission from CDC specifies LOINC as an applicable standard, however the hyperlink is to PHINVADs vocabulary “hot topics” page: If you search for “Specimen Type” there are at least 13 different value sets for Specimen Type. If/when ONC cites vocabulary standard(s), please provide a hyperlink which is a direct link to the applicable vocabulary.

The CDC submission also references Supporting Artifacts which “…are standard elements in HL7 laboratory messaging: https://www.cdc.gov/elr/index.html”.


HL7’s electronic laboratory reporting (ELR) Implementation Guide that was cited for Meaningful Use Stage 1: “HL7 Version 2.5.1 Implementation Guide: Electronic Laboratory Reporting to Public Health, Release 1 (US Realm)”. The ELR requires V2.5.1 HL7 Table 0487 for Specimen Type table, which is obviously not LOINC codes. This inconsistent reference to multiple terminologies in the original submission may impede interoperability without clarifying the contextual definition. Specimen type may not be populated (although SPM-4 is required in ELR) but some PHAs prefer specimen source (OBR-15), which has been deprecated in HL7, to be reported instead.

When ONC cites vocabulary standards for this data element, we suggest the HL7 V2 terminology referenced in the ELR be cited since the ELR IG is referenced in Meaningful Use (as of Stage 1) and deployed in all US Public Health Agencies. Some PHAs prefer SNOMED CT for specimen type, however the SNOMED terminology is not totally in synch with HL7 Table 0487 values referenced in the ELR. There is a mapping from HL7 Table 0487 to SNOMED CT which might be referenced as a resource; it is available here: Conceptmap-example-specimen-type - FHIR v4.0.1 (hl7.org).
ELR: http://www.hl7.org/implement/standards/product_brief.cfm?product_id=98

Laboratory/Result Status
https://www.healthit.gov/isa/taxonomy/term/2441/draft-uscdi-v3
Data Element: Representing the stage of completeness of a result of a laboratory test.
Original Submission:
From CDC: | Interoperability Standards Advisory (ISA) (healthit.gov)
ACLA Comment:
Please clarify the result status element and whether it is for the panel or each individual test. For example, a Complete Blood Count (CBC) is the panel, and the White Blood Count (WBC) is one individual test within the panel.

The standards referenced in the original submission do not include HL7 Version 2.5.1 Implementation Guide: Lab Results Interface (LRI); Release 1 (US Realm) which was required by Meaningful Use Stage 2 and the HL7 Version 2.5.1 Implementation Guide: Electronic Laboratory Reporting to Public Health, Release 1 (US Realm) required for Meaningful Use Stage 1 and currently used for COVID-19 and other STLT health department reporting.


When ONC cites vocabulary standards, we suggest the HL7 V2 terminology referenced in the LRI and ELR be cited as a required terminology since these terminologies are currently used for laboratory result reporting.


LRI: http://www.hl7.org/implement/standards/product_brief.cfm?product_id=279


ELR: http://www.hl7.org/implement/standards/product_brief.cfm?product_id=98

ACLA Comments USCDI V3_04.18.2022 - final submitted.pdf

Accounting of Disclosures

I would like to recommend that a critical data element for USCDI API access are the Accounting of Disclosures.

Where each Disclosure is made available using FHIR AuditEvent, and following the IHE BasicAudit Implementation Guide, Privacy Disclosure Audit Message profile -- https://profiles.ihe.net/ITI/basicaudit/content.html#3577-privacy-disclosure-audit-message

This Privacy Disclosure Audit Message could also carry more than just the disclosures that meet the HIPAA Accounting of Disclosures. The expansion beyond HIPAA specifics is not part of this recommendation, but is encouraged.

The access to the Privacy Disclosure events enables the Patient to understand how their data are used, which is an important Privacy Principle https://healthcaresecprivacy.blogspot.com/2015/04/privacy-principles.html

Access to the Privacy Disclosure events also enables the Patient to notice when inappropriate accesses happen. This can help a Covered Entity detect inappropriate access sooner than they might detect otherwise. 

The IHE BasicAudit Implementation Guide further covers how a Patient may use an application implementing the Audit Consumer -- https://profiles.ihe.net/ITI/basicaudit/volume-1.html#1524-basicaudit-overview. The IHE BasicAudit Implementation Guide also covers how all other accesses (beyond Accounting of Disclosures) could be recorded in AuditEvent so that the Patient would be able to access AuditEvents where the Patient is a agent or entity. -- https://profiles.ihe.net/ITI/basicaudit/index.html

CMS-CDC Joint Comment on USCDI v3

On behalf of the Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC), we submit the attached comment on USCDI Draft version 3 for consideration. We thank you for the opportunity to comment on the draft version 3 of the US Core Data for Interoperability (USCDI). CMS and the CDC rely on standardized data to assess quality of care, track health problems, and promote actions that safeguard the health of individuals across the nation.  We appreciate the Office of the National Coordinator’s (ONC) leadership in this space and strongly support USCDI’s role as a central mechanism to identify and implement a foundational set of electronic health information for interoperable health data exchange.  We were pleased to see that version 3 includes several priority data elements that are essential to both improved public health and healthcare quality data, including health insurance information, pregnancy status, disability status, laboratory specimen type, and occupation. While both of our respective agencies will be providing independent feedback on USCDI version 3, the attached letter reflects a subset of shared, priority elements CMS and CDC jointly recommend should be included in version 3.

USCDIv3_CMS CDC joint comment letter_03252022.pdf

CMS-CDC Joint Comment on USCDI v3

On behalf of the Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC), we submit the attached comment on USCDI Draft version 3 for consideration. We thank you for the opportunity to comment on the draft version 3 of the US Core Data for Interoperability (USCDI). CMS and the CDC rely on standardized data to assess quality of care, track health problems, and promote actions that safeguard the health of individuals across the nation.  We appreciate the Office of the National Coordinator’s (ONC) leadership in this space and strongly support USCDI’s role as a central mechanism to identify and implement a foundational set of electronic health information for interoperable health data exchange.  We were pleased to see that version 3 includes several priority data elements that are essential to both improved public health and healthcare quality data, including health insurance information, pregnancy status, disability status, laboratory specimen type, and occupation. While both of our respective agencies will be providing independent feedback on USCDI version 3, the attached letter reflects a subset of shared, priority elements CMS and CDC jointly recommend should be included in version 3.

USCDIv3_CMS CDC joint comment letter_03252022.pdf

HL7 Gender Harmony Project, Official Comments

The HL7 Gender Harmony Project (list of participants can be found here) respectfully submits the attached comments and recommendations. 

HL7_GH_uscdi_response_03142022.pdf

NCPDP Comments

      • As the National Council for Prescriptions Drug Programs (NCPDP) broadens the NCPDP Telecommunication Standard to incorporate clinical data, NCPDP will evaluate USCDI for utilization, as appropriate, to communicate this information.
      • NCPDP strongly encourages ONC to add the National Drug Code (NDC) for use as a primary identifier of medication. Because of the pervasiveness of the NDC, the majority of NCPDP standards include the NDC as the primary drug identifier. The NCPDP Telecommunication Standard is used to process over 4.5 billion[1] claims transactions per year, the vast majority of which include the NDC of the dispensed prescription. 1.91 billion[2] prescriptions are sent electronically from prescribers to pharmacies using the NCPDP SCRIPT Standard, where NDCs are almost exclusively used to represent the drug prescribed. Additionally, the industry uses the NDC in other important electronic prescribing transactions to accurately report the specific product in patient medication history, prescription renewals, prescription transfers, prior authorizations, medication changes, product recalls, adverse event reporting, REMS reporting and Real Time Prescription Benefit. RxNorm does not identify the specific packaged product dispensed and would not be as useful in such transactions.

 

[1] 2021 data based on projected claim counts from the IQVIA® National Prescription Audit (NPA™) database

[2] 2020 data :https://surescripts.com/news-center/national-progress-report-2020

CMS-CCSQ Comment on USCDI Draft Version 3

On behalf of The Centers for Medicare and Medicaid Services (CMS) and The Center for Clinical Standards and Quality (CCSQ), we submit the attached comment on USCDI Draft version 3 for consideration. We certainly recognize there are many needs and multiple perspectives to consider that must be balanced by ONC and the USCDI Committee, and thank ONC for the opportunity to contribute comments.

CMS continues to support the USCDI as the central mechanism in defining the foundational set of electronic health information for interoperable health exchange. This, in turn, defines what data patients have access to, and also helps define what we are sharing across sites to support clinical care and best outcomes. CMS has committed to transforming its quality measurement to digital, and the USCDI as well as the USCDI+ allows us to build on a foundational framework for this transition.

CMS was pleased to see several of our priority data elements added to draft version 3, including health insurance and disability status information, which support the goal of reducing disparities in care. Despite these great additions, there are still several critical elements we feel must be added to USCDI version 3 to support interoperability, patient care and access to data. CMS recommends the attached data elements also be added to USCDI version 3. We have also entered comments for each recommendation under the elements in this ONDEC system.

CMS-CCSQ USCDI V3 Public Comment Letter.pdf

CMS-CCSQ Comment on USCDI Draft Version 3

On behalf of The Centers for Medicare and Medicaid Services (CMS) and The Center for Clinical Standards and Quality (CCSQ), we submit the attached comment on USCDI Draft version 3 for consideration. We certainly recognize there are many needs and multiple perspectives to consider that must be balanced by ONC and the USCDI Committee, and thank ONC for the opportunity to contribute comments.

CMS continues to support the USCDI as the central mechanism in defining the foundational set of electronic health information for interoperable health exchange. This, in turn, defines what data patients have access to, and also helps define what we are sharing across sites to support clinical care and best outcomes. CMS has committed to transforming its quality measurement to digital, and the USCDI as well as the USCDI+ allows us to build on a foundational framework for this transition.

CMS was pleased to see several of our priority data elements added to draft version 3, including health insurance and disability status information, which support the goal of reducing disparities in care. Despite these great additions, there are still several critical elements we feel must be added to USCDI version 3 to support interoperability, patient care and access to data. CMS recommends the attached data elements also be added to USCDI version 3. We have also entered comments for each recommendation under the elements in this ONDEC system.

CMS-CCSQ USCDI V3 Public Comment Letter.pdf

Patient Demographics Data Class

Please consider renaming “Patient Demographics” to “Patient Information” or something generic enough to cover "Occupation" + "RelatedPerson"

Work Information Elements

The Honorable Micky Tripathi

National Coordinator for Health Information Technology

U.S. Department of Health and Human Services

330 C Street SW, 7th Floor

Washington, D.C. 20201

Re: Comments on U.S. Core Data for Interoperability (USCDI) Version 2

Dear National Coordinator Tripathi:

Founded in 1988, the Association of Occupational and Environmental Clinics (AOEC) is a membership organization of occupational and environmental health (OEH) clinics and professionals dedicated to providing the highest standard of multidisciplinary, patient-centric care that is public health- and prevention-oriented. AOEC represents over 60 OEH clinics throughout the US, Canada, and Germany. Through research collaboration and information sharing our organization enhances the practice of clinical occupational and environmental medicine and promotes excellence in occupational and environmental health.

In 1991, the AOEC began developing a database system for use by AOEC clinics to help identify emerging occupational and environmental health concerns. This database includes diagnostic and exposure data on occupational and environmental illnesses and injuries for patients seen in member clinics. Clinics were asked to submit data on patients if they believed there was an association between the exposures/hazards and diagnosis. Between 1991 and 2019, over 25,000 patient reports were entered into the AOEC database.

The AOEC database collects a limited set of data. To ascertain the full impact of occupation and industry on health, the data must be more robust. The proposed addition of work information in the USCDI is a major step in obtaining more complete data.

The experiences of the Covid-19 pandemic have shown the need for such data. Most workers diagnosed with work-related COVID-19 infections were seen in emergency rooms, urgent care centers, or primary medical practices. At present, the information from these visits cannot be used to identify common workplace sources of COVID-19 infection. The Bureau of Labor Statistics (BLS) and the Occupational Safety and Health Administration (OSHA) provide some information, but the injury and illness numbers that OSHA and the BLS collect are self-reported by employers. Further, at present OSHA guidance to employers’ states that only Covid-19 hospitalizations need to be reported to OSHA if the hospitalization occurred within 24 hours of exposure (https://www.osha.gov/news/newsreleases/national/09302020). These obstacles lead to a serious undercount of occupational COVID-19 infections and significant delays in identifying workplace sources of COVID-19 outbreaks, and impedes efforts to control the pandemic.

Therefore, we ask, with some urgency, that USCDI include the workplace data elements as outlined above.

Sincerely,

Katherine Kirkland, DrPH, MPH

Executive Director

Association of Occupational and Environmental Clinics

PO Box 91096

Washington, DC 20090

kkirkland@aoec.org

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