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.
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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.
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
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.
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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.
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 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.
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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.
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.
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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.
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.
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.
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.
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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.
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.
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.
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.
Physiologic measurements of a patient that indicate the status of the body’s life sustaining functions.
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.
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.
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.
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.
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.
- 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.
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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.
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.
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.
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.
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 wgsuarez on
Kaiser Permanente Comments on USCDI Version 2
Overall Comments
-- Definitions: ONC should more clearly define data elements in the USCDI master document (both USCDI v1 and USCDI v2). ONC does not provide any ‘data dictionary’ reference for data elements. Also, having no applicable standard reduces the value of the USCDI and creates confusion in how health care organizations interpret each data element. Thus, we strongly recommend that ONC develop and publish specific, detailed definitions for every data element in the USCDI. We also recommend that ONC identify applicable standards for elements currently lacking them. As an example, when implementing USDCI v1, we had trouble interpreting what qualifies as a progress note, what’s required for provenance, and other definitional issues. The USCDI seems to assume there is a common set of terminology used across the industry that is universally understood. As we discovered, that is not the case. Being that USCDI is now intended for the masses, it would be great if it could be made easier to use by including definitions. Organizations shouldn’t have to depend on health care coding experts to understand what is required.
-- Coordination: We are concerned about the relationship among the ONC ISA, the USCDI, and requirements for eHI (electronic health information) into the future. According to final regulations, the USCDI will be superseded by eHI starting October 2022, when it is likely ONC would have issued a Version 3 of the USCDI. ONC should address the relationship between these newer versions and the eHI.
-- ONDEC submission system improvements and USCDI Portal: There is valuable information included in the new proposed data classes and data elements (a use case description, estimated number of stakeholders using data element, health care aims, applicable standards, additional specifications). However, all that information seems to get lost when the data element becomes part of the formal USCDI Version. Additionally, it is worth noting that the URL links of several data classes and data elements in the USCDI portal under “V2” and “Level 2” sections do not work.
-- Submission Evaluation Criteria: ONC and HITAC considered four main criteria to evaluate each of the data classes/data elements submitted for consideration: 1) Maturity of Current Standards; 2) Maturity of Current Use; 3) Maturity of Current Exchange; and 4) Use Cases (# Stakeholders Impacted). The threshold for classifying data classes and data elements as Level 1 or Level 2 is too low. For example, limited production in 1 or 2 systems, or exchange between 2 or 3 organizations with different EHRs will get a data class/element to become classified as Level 1; and in production in more than 2 systems, or exchange between 4 or more organizations with different EHRs would get a data class/element to be classified as Level 2. Those thresholds should be much higher, particularly for Level 2 elements (as a suggestion, consider for Level 1, Data Classes/Data Elements with limited production in 9 or 10 systems, or exchange between at least 10 organizations with different EHRs; and for Level 2, Data Classes/Data Elements in production in more than 10 systems, or exchange between 11 or more organizations with different EHRs). We also recommend ONC consider the value of data elements for the end users, including consumers, primarily, but also providers, public health, health plans and others).
-- Recommendations regarding Version 3 submission cycle: We are concerned that the evolution of the USCDI is moving too fast to allow appropriate stakeholder consideration, transition, implementation, and evaluation. We are also concerned with the possible regulatory adoption of a future version of USCDI and the jump from Version 1 to a Version 3 or Version 4 (as an example) will be quite significant, costly, and unduly burdensome. Lastly, we are concerned that the new Diagnostic Imaging and Encounter Information data classes will be complex to enable the functionality needed, time consuming and costly.
Question 1 – Was the extent and scope of the proposed change appropriate?
Changes to USCDI v2
-- New “Diagnostic Imaging” Class and Data Elements: The data class seems to be appropriate, as it is available from systems. With respect to the data elements, the difference between Diagnostic Imaging Narrative and Diagnostic Imaging Report is not clear. Thus, we recommend ONC clarify the difference between the two. If there is no difference, ONC should combine these into a single element.
-- New “Encounter Information” Class and Data Elements: We have no concerns about adding this new class; however, we are concerned about the Encounter Type element, as the proposal includes multiple different types of applicable code standards (SNOMED, ICD-10, HL7 Value Set, Discharge Disposition code set, VSAC code set). Mapping encounter types across organizations will be challenging. For Encounter Time, it will be important to clarify if this will be the start time, length of appointment, scheduled time versus actual time, or scheduled length versus actual length. It will also be important to clarify what does Encounter time look like for Inpatient, ED and Ambulatory.
-- New data elements under “Care Team Member(s)” data class: Under “Provider Identifier” there are two separate and unrelated applicable standards referenced: 1) NPI and 2) Provider Taxonomy. These two codes refer to two distinct characteristics of providers and should not be combined within a single element. Also, we want to point out that displaying the correct taxonomy code of a provider will require complex logic, given that many providers have multiple taxonomy codes, due to multiple specialty services they provide.
-- New data elements under “Problems” data class: As we noted above in our overall comments, the data element, “Problem,” does not have a definition that covers both past and current problems. In many instances, organizations distinguish these; the “Current Problem” list is readily available as having more immediate clinical relevance. It will be important to add a definition to the data element “Problem” and clarify whether it includes past and present conditions.
Level 2 Data Classes and Data Elements
-- We are concerned with the significant expansion of data classes and data elements in the Level 2 category, described as “data classes/elements that demonstrate extensive use in systems and exchange between systems, use cases that show significant value to current and potential users, and would clearly improve nationwide interoperability.” While some of the classes and elements may be valuable in specific cases, they currently have limited collection, use, and exchange in existing systems (e.g., travel information, social history, social determinants of health, health insurance).
-- We reiterate our concern that all classes and elements should have clear definitions.
Level 1 and Comment Sections
No comments at this time.
Question 2 – Were the right data classes and elements added in the proposed new version?
-- The two new classes, and the reclassification of certain clinical notes into other classes are appropriate
Question 3 – Are any of the proposed additional data classes, elements, or standards problematic?
-- Our primary concerns are that some elements lack clear definition, and there is no mapping between the applicable standard and the documentation in the electronic system of the organization. For example, organizations have noted difficulties interpreting what qualifies as a clinical note (a progress note, for example), what is required for provenance, etc.
-- Diagnostic Imaging and Encounter Information Data classes need detailed information for an Organization to implement the technical solution. Current information and standard provided is not enough for achieving a successful implementation.
Question 4 – Are there additional data classes or elements that have been categorized by ONC as Level 2 or even Level 1 that you believe should be added to USCDI V2?
None at this time.
Submitted by Mark Savage on
UCSF's Center for Digital Health Innovation on USCDI v2
The University of California, San Francisco’s Center for Digital Health Innovation submitted the attached comments on new data classes and elements for version 2 of the U.S. Core Data for Interoperability. These comments were submitted October 23, 2020. Now that ONC has published its draft of USCDI v2 for public comment, UCSF's CDHI may submit additional comments as well.
We appreciate the considerable work that ONC has devoted to the Common Clinical Data Set (CCDS) and its next evolution, the U.S. Core Data for Interoperability version 1. Version 1, however, was only a “modest expansion” of the Common Clinical Data Set. As a health care provider, we urge ONC to add numerous additional data elements now so that they, too, become available for better health care, for key national use cases such as COVID-19 and virtual care, and for the nationwide learning health system we need. According to ONC, technical specifications are already available for 46 of 50 data classes ONC listed for candidate and emerging status, and all 50 are “critical to achieving nationwide interoperability.”
To illustrate the importance of adding the missing data elements now, we tested them against two COVID-19 use cases and asked which missing structured data elements are necessary or important now for health care in the midst of the COVID-19 pandemic. Not surprisingly, most were necessary or important.
If you or your staff have any thoughts or questions about these comments, please feel free to contact me at Mark.Savage@ucsf.edu.
Yours truly,
Mark Savage
Submitted by bkeeler89 on
Redox Engine Comments on Draft USCDI v2
Redox is a platform for healthcare applications to integrate to healthcare organizations regardless of EHR, as well as nationwide networks like Carequality, HIEs, and state registries. Our interest in USCDI is based on being well-positioned to see existing gaps for the most common workflows across this broad variety of stakeholders.
General comments on updates
We feel the proposed changes are appropriate but decidedly conservative and iterative. The change represents minor updates to two data classes (Care Team Members and Problems) and two net new data classes (Encounters and Imaging)
- For the updates to existing classes, we feel these should already be implicit when implemented. For instance, Problems are represented as Conditions in FHIR, which have the facet of OnsetDate already, so these updates in USCDI v2 are just prescriptive requirements to guide imprecise or careless vendors.
- In regards to the creation of Encounters class, we would expect to see this data class extended to properly encompass a patient’s outpatient appointments. With the current data class and element definitions, we do not feel that vendors will necessarily expose the Appointment resource or sufficient detail around scheduled encounters, such as scheduled provider or visit type (which may differ/be more granular than encounter type). Giving patients access and visibility into their appointment, both historic and future, adds tremendous power to patient facing applications in helping them understand and manage those administrative details (and benefits healthcare organizations in perhaps reducing no-show rates).
- In regards to the creation of Diagnostic Imaging class, we support and endorse this addition. We would like to see the further addition of the image itself. Although we recognize the difficulty of expanding scope to data included in the PACS system of the healthcare organization, the impact for patients will be tremendous. Allowing portability of radiology and other imaging will drastically change the current CD/DVD driven workflows and ease transitions of care between organizations. We also support exposing all clinical images/files (not just diagnostic) stored to the patient chart.
Data elements already available commonly and standardly in EHRs
Several data classes in Level 2 that are not in USCDI V2 such as Social History or Orders are made available standardly to patients and other providers today (and for several years) via the VDT provisions of Meaningful Use and CDA exchange via Carequality and Commonwell. There are also additional Level 2 elements that should be readily available in EHR systems such as Encounter Location. We believe that these would be low lift for healthcare providers and their vendors, but of value for the patient.
Data elements offering largest value to patients still missing
We strongly believe that to increase the value of USCDI to healthy but unengaged patients, core administrative data is among the most important to define and expose, such as the aforementioned Appointment information. Additionally, Insurance (defined in Level 2), Advanced Directives (Level 1), Referral (comment), additional patient demographics (multiple levels) and financial information are core to the patient experience and have the greatest potential to increase patient engagement in healthcare activities once exposed, aggregated and understood. We strongly believe that to increase the value of USCDI to the sickest, most chronic patients, specialty-specific data is also among the most important to define and expose, such as the Ophthalmic Data (Level 2), pregnancy/obstetrics data (comment under Observation), and oncology data (comment under Observation)
Public Health considerations
Much of the commentary surrounds public health response and tracking trends at the population level but the updates do little to help in that regard. With the inclusion of the Level 2 proposed elements on Immunizations and Laboratory sections, the USCDI updates could make an impact in the ongoing efforts to fight the pandemic and expected improvements to public health infrastructure to come. Given this dataset will also be implemented for bulk data exchange, this may also be beneficial for CEHRT requirements, in that some could be replaced by relatively small USCDI expansion (Syndromic surveillance, vaccine registries, etc.)
Submitted by Summit Healthc… on
Comments re: USCDI v2 DRAFT
Summit Healthcare Association submits its comments to the proposed USCDI v2:
- Under the data class “Encounter Information,” data element “Encounter Type” – how does one indicate observation status? It does not appear to fall under any listed SNOMED encounter type.
- Under the data class “Problems,” data element “Date of Resolution” – This may be problematic for routine, acute conditions such as the common cold or flu, for which patient is seen for treatment, but is not seen follow up. Therefore, in this instance, how would one determine the date of resolution?
Submitted by HDuncan.CAP on
CAPComments_USCDI.02
This field is for general comments on the USCDI. To submit new USCDI data classes and/or data elements, please use the USCDI ONDEC system: https://healthit.gov/ONDEC
Submitted by cbush on
Division of Vital Statistics Support for Death and Birth items
The Division of Vital Statistics (DVS) within CDC’s National Center for Health Statistics (NCHS) supports inclusion of submitted mortality and natality data elements into USCDIv2. The mortality data elements include Cause of Death Information, Autopsy Performed, and Date and Time pronounced dead. These mortality data elements requested not only support multiple public health use cases, but they also support the clinical information reported on death certificates. This will inform mortality reporting about public health challenges, determine life expectancy and compare death trends with other countries.
The natality data elements include Clinical Notes for Newborn, Pregnancy History, Apgar Score, Estimated Date of Delivery, Gestational Age at Birth, Last Menstrual Period (LMP), Number of Fetal Deaths This Delivery, and Patient Birth Place. Currently there are natality elements that have progressed to level 2, and to compliment the reporting of natality holistically are a reason these Comment Level items should also be included within the Level 2 inclusion. These data elements track health trends that includes pregnancy risk factors and preterm births.
The inclusion of these elements in USCDIv2 would have a significant impact on mortality and natality reporting by reducing the burden of duplicative data entry and streamlining the process flow. The primary objective is to improve the timeliness, quality, and sustainability of vital statistics reporting. The inclusion of these elements would not only support national level reporting but also benefit State partners who are the first line of receiving these data and clinical providers who are on the first line of sending these data. DVS has been working with State partners and their electronic registration systems as part of modernization efforts. Inclusion of these elements would support interoperability among the vital statistics ecosystem. DVS and State partners have been focusing working towards using the HL7 FHIR standards that adhere to the US Core resources within their implementation guides when possible.
Submitted by djdonovan on
Highmark Health Letter of Support for Gravity Project Submission
This letter is written in support of The Gravity Project’s submission to the Office of the National Coordinator to advocate for the inclusion of Social Determinants of Health (SDOH) in the U.S. Core Data for Interoperability. As one of the nation’s largest integrated healthcare delivery systems, Highmark Health believes this integration is critical to improve the health and well-being of those we serve.
Public health professionals have long known that social and environmental determinants of health explain most of a person’s and population’s health status. The health care delivery sector is now understanding that the delivery of traditional health care accounts for only 20% of one’s health. The COVID-19 pandemic has highlighted this reality daily across the nation. The Gravity Project’s submissions would add critical domains such as food insecurity, housing instability, transportation insecurity, social isolation, and stress to the USCDI, integrated with core clinical activities such as assessments, diagnoses, interventions, and outcomes.
The need for inclusion of SDOH as a new data class in USCDI is a requisite to capturing social risk and supports a focus on and prioritization of use cases with a high impact on the triple aim, the widely accepted policy objective of HHS that refers to improving the experience of care, improving the health of populations, and reducing per capita costs of health care. The fact that SDOH accounts for 80 percent of health status at a population level and that there is no consistent method to document and communicate these factors during a health care encounter emphasizes the urgency of a national standard approach across the health care system. The implementation of these standards is necessary to drive reductions in missed appointments, cost savings from preventable health events, culturally competent care, increased care plan compliance, reduced administrative burden, promoting effective investment in community health programs, and leveraging critical data to improve patient outcomes.
Health care’s transition from a fee-for-service model to value-based care adds an additional imperative for SDOH, since these elements will become increasingly necessary to establish appropriate and equitable reimbursement of health care service providers and advance reimbursement models for community based organizations. Without standards and code sets, health plans will be challenged to evolve their value based reimbursement programs to include social risk.
Please accept this recommendation on behalf of Highmark, for The Gravity Project’s submission to the USCDI. Should you have any questions or need additional insight please don’t hesitate to contact me at (412) 721-6800 or via email at Deborah.donovan@highmarkhealth.org.
Submitted by zbarber on
NYeC Support for Gravity Project Submission
The New York eHealth Collaborative (NYeC) supports the inclusion of key social determinants of health (SDOH) data elements as submitted by the Gravity Project in the U.S. Core Data for Interoperability (USCDI) Version 2. New York State has been a leader in requiring interventions and data collection to address SDOH in Value-Based Payment as part of the Medicaid program, which underscores the importance of this work. The Gravity Project’s submissions would add critical domains such as food insecurity, housing instability, transportation insecurity, social isolation, and stress to the USCDI, integrated with core clinical activities such as assessments, diagnoses, interventions, and outcomes. Widespread capturing of standardized SDOH data is critical to understanding and addressing health disparities and improving health outcomes for individuals and communities.
Submitted by sbzemel on
Support for the Gravity Project's submission on SDOH
Please see the attached letter for Providence St. Joseph Health's support to the Gravity Project's submission for two approaches for including social determinants of health data in the USCDI.
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Fig 1 The "Data Class" and "Data Element" dropdown menus allow users to specify the exact content they wish to comment on.
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Fig 3 The "Comment on another data element" link enables users to create multiple comments addressing different elements within a single submission.
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Fig 4 The "File Upload" section permits users to attach supporting documentation that supplements their written comments.
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Fig 5 A red triangle with exclamation mark indicator appears next to the “Return to saved Comment” button when draft comments are saved in the system.
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Fig 6 The review screen allows users to verify comment content and make any necessary modifications before final submission.
Submitted by Grace Cordovano on
USCDI Draft v2: Comments from Patient & Carepartner Perspective
General Overview
Specific Feedback
Allergies & Intolerance: Many people are allergic to things that are not a medication that they can encounter in a clinical setting, such as latex. This won't have a medication name or drug class.
Assessment & Plan of Treatment: Is this only capturing the clinical treatment plan? Is this capturing social determinants of health (SDoH)? If a health professional is not aware of various prominent barriers a patient is living with, the clinical treatment plan that is documented will fully fail the patient. For example, prescribing an expensive infusion treatment that is not covered by a patient's insurance company may cause significant harm to the patient as treatment is not affordable or accessible. If this is not understood before the patient leaves the clinic, a patient may learn about the treatment being not covered and simply not come back to the clinic and give up. This leads to disease progression and exacerbation of symptoms with the potential for eventually needing emergency room care. By understanding what SDoH factors may negatively impact a clinical treatment plan, adjustments may be made proactively as well as connecting the patient to community support and financial assistance resources. Recommend building a framework to capture elements of social determinants of health (SDoH) for future draft versions for prioritization from level 2.
Care Team Members: Is this only capturing clinical care team members? To be progressive, we must capture and include a patient's primary carepartner, advocate, executor of their estate, personal representative, etc. as the majority of care, especially in the chronic, life-altering, life-limiting settings, happens outside of the four walls of medicine requiring the support of non-clinical care team members. The Care Team Members Data Class and Data Element need more detail in the USCDI draft v2 description on page 6 to clarify ambiguity.
Clinical Notes: Operative notes are critical to patient continuity of care and patient safety. It is important to emphasize that operative notes are one of the only pieces of information that alert patients and their carepartners to the fact that tissue and biological samples may have been harvested during surgery and have been submitted for pathology and/or laboratory analysis. Operative notes need to be included under Clinical Notes in draft v2.
Diagnostic Imaging Narrative: An Imaging Narrative should not be available to be extracted without all the accompanying essential components of the imaging report. The concept of an Imaging Narrative is also unclear. Data Elements should be reflective of the wording used in the real world. An Imaging Narrative is typically referred to as the Findings/Impressions/Summary section of the imaging report and should be referred to as such for consistency.
Immunizations: Essential public health safety, reporting, and information exchange throughout the pandemic & for post-pandemic public health monitoring.
Laboratory:
Medications:
Problems: Date of Resolution is not broadly applicable to people living with chronic illness, life-altering, life-limiting conditions, disability, rare disease, terminal illness, and active death care and end-of-life. This is a vague data element that can bring great harm to patients should it be documented incorrectly or incompletely. The TF must be conscious of the potentially severe negative impact on patients' lives with respect to matters such as disability benefits should the data element be captured incorrectly or not comprehensively. Recommend removing from USCDI draft v2.
Procedures: Do surgical/operative reports/notes currently fall under this category?
Smoking Status: Tobacco Use more accurately describes the spectrum of individual behavior being captured in a less stigmatizing manner. TF should consider revising the data class and element name to "Tobacco Use".
Other: