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
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.
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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.
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 Hiral on
UI Health Comments on Draft USCDI v6
UI Health
April 14, 2025
Office of the National Coordinator for Health Information Technology
Department of Health and Human Services
330 C Street SW
Washington, DC 20201
Subject: Final Consolidated Comments on USCDI Version 6
Dear ONC Review Committee,
On behalf of UI Health, we appreciate the opportunity to submit our comments on the proposed updates to the United States Core Data for Interoperability (USCDI) Version 6.
USCDI has grown substantially since its initial release with each version introducing new data elements that advance interoperability and clinical care. We recognize the maturity the USCDI dataset has reached and understand the need to be judicious about further inclusions. The latest version reflects efforts to address high-impact, widely applicable use cases without overwhelming implementers.
We provide the following feedback in response to specific updates and proposed inclusions:
1. Facility Address
We support the addition of the Facility Address data element to USCDI. However, we urge ONC to provide clearer and more specific guidance regarding its definition and exchange expectations. While we understand that the current intent is to identify a facility address for large organizations, in practice, healthcare facilities typically maintain multiple address types, each serving distinct operational and clinical purposes:
- Mailing Address: Used for general correspondence and administrative functions (e.g., payroll).
- Physical/Service Location Address: The actual site where patients receive care or present for appointments.
- Billing Address: Used for claims processing and financial transactions.
To promote greater consistency and accuracy in health data exchange, we recommend that ONC:
- Explicitly recognize and define the existence of multiple address types per facility.
- Clarify which address types should be included in USCDI exchange for specific use cases (e.g., patient encounters, provider directories, reporting).
- Consider introducing a data element to indicate the address type (e.g., "mailing," "service location," "billing"), enabling systems to appropriately interpret and use the information.
Without this level of specificity, inconsistent interpretations of “Facility Address” could hinder interoperability and limit the effectiveness of data exchange. Clear guidance from ONC in the finalized USCDI Version 6 definitions is essential to ensure accurate, aligned use of this foundational data element across healthcare settings.
2. Family Health History
We endorse the inclusion of Family Health History as a core data element. This data has long been used in structured documentation and clinical decision-making, especially for preventive screenings and personalized care. The USCDI’s recognition of its value further standardizes its use across care settings and enhances its availability at the point of care.
3. Unique Device Identifier (UDI)
We commend ONC for broadening the Unique Device Identifier to cover all medical devices—not just implantables. This is a necessary and forward-thinking change that improves traceability, safety surveillance, and recall processes. Our general assessments with Epic confirm readiness to align with this shift, as we already capture UDI data within Epic and plan to extend this to non-implantable devices. This change represents a significant leap toward comprehensive device interoperability.
4. Problems Data Class – Date of Onset
We acknowledge the ONC's proposed update for the "Problems" data class, specifically concerning the "Date of Onset" element. We concur with the observation that the precise date of onset for a problem is often difficult to ascertain. Patients may not recall the exact date, or the onset may be gradual or unclear.
Therefore, we recommend that the USCDI guidance for the "Date of Onset" within the "Problems" data class should emphasize:
- The potential for imprecision: Recognize that the "Date of Onset" may often be an estimated date, a range, or even just a month or year.
- The importance of capturing the best available information: Encourage providers to record the most accurate information available, even if it is not a precise date.
- Flexibility in data exchange: When exchanging "Date of Onset" information, receiving systems should be prepared to handle varying levels of precision (e.g., full date, month/year only, estimated date).
- Consider allowing for a qualifier or indicator of imprecision: Exploring the possibility of including a qualifier to indicate that the "Date of Onset" is estimated or imprecise could enhance the clinical utility of this data element.
By acknowledging the inherent challenges in accurately determining the "Date of Onset," the USCDI can promote more realistic and useful data capture and exchange within the "Problems" data class.
5. Care Plan
Regarding the "Care Plan," we note the complexity and potential overlap with existing USCDI concepts like patient goals, care experience preference, health concerns, assessment, and plan. We suggest the ONC clarify how the proposed "Care Plan" addition is distinct from these existing elements and consider a mechanism to construct a comprehensive care plan using the already available USCDI data elements, potentially making them more robust to encompass the necessary components. Clear differentiation and leveraging existing elements are crucial for a more coherent and less confusing addition of the "Care Plan" to USCDI Version 6.
6. Portable Medical Orders in the Context of Advance Care Planning
We offer the following consolidated comments regarding the potential integration of Portable Medical Orders (POLST) within USCDI v6:
In essence, our feedback emphasizes the need to integrate Portable Medical Orders thoughtfully within USCDI, primarily as a key component of Advance Care Planning. These orders are distinct from Advance Directives—serving as immediately actionable medical instructions, especially for frail or seriously ill patients, such as those related to code status. To support appropriate use, USCDI should clearly differentiate Portable Medical Orders from related data classes like Advance Directives and Treatment Intervention Preferences. Additionally, thoughtful organization within the USCDI structure is essential to ensure providers and systems can accurately interpret, exchange, and act upon this information in real-world care settings. Addressing ambiguities within the existing "Orders" class remains a critical step to achieving this clarity and interoperability. We believe that thoughtful inclusion of Portable Medical Orders will improve data consistency and ensure that patient preferences are honored across settings and transitions of care.
Final Thoughts
We appreciate the opportunity to comment on USCDI Version 6 and commend ONC’s continued efforts to strengthen interoperability through carefully scoped and meaningful updates. This version reflects a thoughtful balance—prioritizing widely applicable, high-impact elements while recognizing the maturity and complexity of the dataset. Our feedback is intended to support clarity, usability, and alignment with real-world care delivery by addressing definitional gaps, refining existing elements, and ensuring that new additions—such as Facility Address, Family Health History, and Portable Medical Orders—are well-integrated and actionable across care settings.
Thank you for your leadership and collaboration as we work together to advance data interoperability that improves care quality, coordination, and patient outcomes.
Submitted by mmoen48 on
We appreciate ASTP's…
We appreciate ASTP's willingness to consider comments from the community regarding USCDI Draft v6. Giving people a voice in their care, so that they can express preferences for treatments they do, and do not want, is a foundational step towards a person-centered healthcare system . USCDI plays an important role in the healthcare technology ecosystem, and MyDirectives in particular looks forward to the continuation of ASTP's willingness to hear from the community and our opportunity to provide thought leadership that is supportive of the work at hand.
Submitted by Solarf3050 on
HL7 Feedback on Draft USCDI v6
Please see attached the comments of Health Level Seven (HL7) International on ASTP/ONC’s Draft United States Core Data for Interoperability Version 6 (Draft USCDI v6) and thank you for the opportunity to provide feedback.
Submitted by shannon.vogel@… on
TMA Comments to ASTP on USCDI Draft Version 6
The Texas Medical Association appreciates the opportunity to submit the attached comments on USCDI Draft version 6.
Submitted by squinn on
American College of Physicians Comments on Draft USCDI v6
Attached please find ACP's comments.
Submitted by C_Hull on
AdvaMed Imaging Draft USCDIv6 Comments
The AdvaMed Medical Imaging Division represents the manufacturers of medical imaging equipment, including magnetic resonance imaging (MRI), medical X-Ray equipment, computed tomography (CT) scanners, ultrasound, nuclear imaging, radiopharmaceuticals, and imaging information systems. Our members have introduced innovative medical imaging technologies to the market, and they play an essential role in our nation’s health care infrastructure and the care pathways of screening, staging, evaluating, managing, and effectively treating patients with cancer, heart disease, neurological degeneration, COVID-19, and numerous other medical conditions.
We are encouraged to see the Assistant Secretary for Technology Policy (ASTP) and Office of the National Coordinator for Health Information Technology (ONC) continue work to improve the US Core Data for Interoperability (USCDI) and enhance interoperability in healthcare—a goal our members share. We submit these comments in support of that shared goal.
Topic 1: Diagnostic Imaging Group
We strongly recommend the elevation of the Level 2 data elements "Imaging Reference", and "Accession Number" to USCDI version 6. These elements align with the ASTP/ONC's prioritization criteria for Level 2 data elements and are crucial for ensuring comprehensive data exchange and interoperability across healthcare systems. Image exchange and availability are critical in enabling the continuum of care across the healthcare ecosystem, as patient populations inevitably transition institutions both by choice and during critical care events. Image exchange is especially important during critical care situations such as mass casualty or emergency transfer to facilities with acute care capabilities, where seconds matter, and having imaging available prior to and upon arrival can be the deciding factor in a patient’s outcome.
HTI-2 introduced "Imaging Links" as a standardized approach to accessing imaging studies, ensuring that images are readily accessible via structured references rather than relying on unstructured reports or proprietary mechanisms. The USCDI should adopt Imaging Reference alongside this "Imaging Links" approach, as it formalizes how images are retrieved and accessed across different health IT systems. This is a policy issue, not a technological or standards topic. Proven interoperable methods exist which have been well documented and tested. By standardizing this mechanism, ASTP/ONC can significantly improve workflow efficiency and eliminate historical barriers to interoperability in medical imaging.
DICOMweb has demonstrated suitability for imaging access across different health IT systems through its use in IHE XCA-I (Cross-Community Access for Imaging), XDS-I.b (Cross-Enterprise Document Sharing for Imaging) and XC-WIA (Cross-Community Web-Based Image Access) Profile, which is currently in public comment. These profiles build on established DICOMweb standards for image exchange across health systems and regional networks.
The Imaging Reference URI retrieval access path can be grouped with the IHE Internet User Authorization (IUA) Profile to incorporate authorization, as outlined in the IHE Web Image Access (WIA) profile, or through the utilization of an authorization server, as demonstrated in the Argonaut SMART Imaging Access initiative. Accession Number is of particular importance in the context of Point of Care Ultrasound (POCUS). In encounter-based imaging scenarios, the Accession Number serves as a vital link between images, reports, and patient encounters within the electronic medical record (EMR). Its inclusion in USCDI version 6 would greatly facilitate the seamless integration of POCUS data into patient records and enhance clinical decision-making.
Topic 2: Medications Group
“Medication Administration” is notably absent from USCDI, posing challenges in obtaining a holistic view of the medication process encompassing prescription, dispensing, and administration. We strongly recommend elevating the Level 2 data element "Medication Administration" to USCDI version 6. This element aligns with the ASTP/ONC's prioritization criteria for Level 2 data elements and is crucial for ensuring comprehensive data exchange and interoperability across healthcare systems.
Medication Administration has been profiled in many HL7 US Realm implementation guides and is considered as a Future Candidate Requirement Under Consideration in US Core. However, because there is no regulatory requirement to support it, it has not been formally profiled in FHIR US Core.
Topic 3: Unique Device Identification (UDI)
We strongly support the inclusion of Unique Device Identifier (UDI) in USCDI v6, as it plays a critical role in device identification and tracking. UDI is already implemented in DICOM (Digital Imaging and Communications in Medicine) and is represented in the UDI Sequence (0018,100A), which is used to reference a device's UDI across multiple equipment-related modules. This enables imaging systems to associate medical devices, such as implants, imaging equipment, and interventional tools, with imaging studies for device tracking and clinical documentation.
Topic 3: Care Team Member(s) Group
We recommend that the ASTP/ONC explore the inclusion of "Care Team Member Privileging" as a potential data element within USCDI. Privileging is the facility-specific authorization granted to a healthcare provider to independently perform specific clinical procedures or services. Within Point of Care Ultrasound (POCUS) scenarios, as specified in the IHE Encounter-Based Imaging Workflow (EBIW) POCUS Option, currently in public comment, privileging plays a crucial role in ensuring that qualified healthcare professionals can authorize POCUS reports and transmit them to the Electronic Medical Record (EMR).
Although privileging is a new addition to EBIW, the concept is well-established across healthcare and extends beyond imaging. Privileging applies to individual healthcare professionals, rather than entire care teams, and has significant implications for workflow management, access control, reporting, and compliance tracking across clinical domains.
We thank you for your attention to these comments and look forward to engaging further as the USCDI revision process continues. If you have any questions, please contact me.
Sincerely,
Carolyn Hull
Senior Director, Global Strategy and Standards
AdvaMed Medical Imaging Division
Submitted by hbuitendijk on
Attached please find Oracle…
Attached please find Oracle Health's feedback on USCDI v6 proposals.
Submitted by knicholoff@ehra.org on
EHR Association Comments on Draft USCDI v6
Please see attached.
EHR Association Comments to ASTP-ONC on Draft USCDI v6_0.pdf
Submitted by RGold on
Vizient Inc. Comments on Draft USCDI v6
We thank ASTP for the opportunity to share recommendations related to Draft USCDI v6. In our comments, we respond to issues raised in SB25-1 and offer our recommendations to constructively improve Draft USCDI v6. However, Vizient believes it is important that additional clarification on several data elements be provided before Draft USCDI v6 is finalized. In addition, we offer recommendations for future iterations of USCDI.
Suggestions for Improvement in the Data Classes or Elements in Draft USCDI v6
As described below, Vizient offers several suggestions related to the data classes or elements included in Draft USCDI v6. Notably, Vizient is generally supportive of several of the data elements and classes proposed to be added to USCDI v6, as we believe they will help support more robust and accurate data collection for hospitals and other providers.
Should Other Data Elements, Already Classified as Level 2 on the USCDI Web Pages, be Added to USCDI v6 Instead, or in Addition to Those in Draft USCDI v6? If so, why?
Vizient recommends adding the below Level 2 data elements to USCDI v6. In support of these additions, use cases are also provided for consideration:
• Medications
- Negation Rationale: This will allow for analyses as to what medication orders are being placed and then subsequently cancelled on a regular basis, in addition to detail on why the medication orders are being cancelled.
•Vital Signs
- Body Mass Index (BMI): Inclusion of BMI would allow for quicker querying of patients in FHIR via BMI rather than having to calculate BMI from the data elements “body height” and “body weight”. A potential benefit to patients is that the addition of BMI would provide more health information, especially as certain patients may not do the calculations themselves (e.g., patients outside of the 2-20 years range for which BMI percentile is included currently).
Data Elements for Future Consideration after USCDI v6
Vizient appreciates ASTP’s efforts to build upon USCDI by providing new versions and additional clarity. For future versions of USCDI, Vizient encourages ASTP to consider further clarifying the following elements and classes:
• Class: Encounter Information
- Add “diagnosis sequence” as an element. This addition would give insight into what diagnoses were associated with the designated encounters.
- Add “encounter status” as an element. This addition would give insight into whether the encounter had already been scheduled, closed, pending for future appointment, or cancelled.
• Class: Patient Demographics / Information
- Add “broadband availability” or “cellular service/smartphone availability” as an element. The addition would help match actionable factors to clinical outcomes in different populations.
• Class: Medication
- Add Discharge Medications: This distinguishes which medications were prescribed for a patient to start/continue from the point of discharge and would minimize confusion with medications prescribed as an inpatient.
- Add Medications Dispensed: This allows for differentiation of which ordered medications were dispensed (e.g., generic). This may be different from what was ordered or administered, as it is the result of a pharmacy system responding to a medication order.
- Add Expiration Date as an element: This would give information on the expiration date of a medication.
Are there Significant Barriers to Development, Implementation, or Use for Any of These Data Elements that Warrant a Change in Definition, or Removal from Draft USCDI v6?
Vizient notes that, as of the time of our comments, we did not encounter barriers to adding to the selected elements. We encourage ASTP to include the elements from the draft USCDI v6 in the final version.
Applicable Vocabulary Standards for Race and Ethnicity Data Elements
In Draft USCDI v6, under the Patient Demographics/Information data class, the applicable vocabulary standards for both race and ethnicity require the use of both the 1997 Office of Management and Budget (OMB) Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity[1] and the Centers for Disease Control and Prevention (CDC) Race and Ethnicity Code Set Version 1.3.[2] As ASTP is aware, the OMB Standards were updated in 2024[3] and these revisions were not incorporated in the amended CDC code set. However, CDC indicates[4] these code sets will be aligned in the future. Vizient appreciates the ongoing process of updates to the vocabulary standards and encourages ASTP to continue to use the most recent CDC Race and Ethnicity Code Set in future iterations of USCDI.
New and Updated Data Elements Included in Draft USCDI v6
Facility Address
In Draft USCDI v6, ASTP adds the new data element “Facility Address”, which includes the physical location of available services or resources, to be used to differentiate specific service locations, link data to track care quality and health outcomes and monitor facility level capacity, such as hospital bed and ventilator availability. Vizient is supportive of the addition of “Facility Address” as a data element because many hospitals currently include this field in their EHRs to share this data for quality and safety purposes including, tracking the patient journey through different sites of care, patient outcomes and to support quality improvement efforts.
Date of Onset
In USCDI v6, ASTP adds the new data element “Date of Onset” as the date or estimated date when signs or symptoms of a condition began to provide more information about the course of disease or other condition providing in existing data elements (e.g., Date of Diagnosis and Date of Resolution). While Vizient supports the addition of this data element to help provide clarity about the progression of the patient’s condition, we believe the data element can be further refined. Vizient suggests clarifying that this data element reflects the onset of symptoms as provided by the patient to allow for more accurate documentation. In addition, such clarification will support communication between providers by providing clear, consistent information about the patient's condition, particularly if patients switch providers or are transferred to different care settings.
Medical Devices Data Element Unique Device Identifier (UDI)– Implantable
ASTP is updating the Medical Devices data element Unique Device Identifier - Implantable to broaden its scope to include all other medical devices, including non-implantable devices. Vizient supports expanding this data element to include non-implantable devices because of the important need for providers to exchange information to effectively identify and report on all device-related patient safety events, improve clinical decision-making to enhance patient treatment, respond to device safety recalls and strengthen the monitoring of medical devices to help ensure their ongoing safety and effectiveness. Additionally, Vizient appreciates ASTP broadening this data element as one data point captured in a single standardized field that recognizes the device identifier, as this will help hospitals manage device information more efficiently and reduce the likelihood of adverse events. For example, if a patient needs to change to a different hospital or provider due to a change in their insurance, the new provider can easily pull their records and link the patient to the device they are using. This will help providers manage device information more efficiently, inform their treatment decisions and improve patient care.
Conclusion
Vizient’s clients include a wide variety of hospitals ranging from independent, community-based hospitals to large, integrated health care systems that serve acute and non-acute care needs. Additionally, many hospitals are specialized, including academic medical centers and pediatric facilities. Individually, our members are integral partners in their local communities, and many are ranked among the nation’s top health care providers. In closing, on behalf of Vizient, I would like to thank ASTP for providing us with the opportunity to comment on USCDI v6. Please feel free to contact me, or Randi Gold at Randi.Gold@vizientinc.com, if you have any questions or if Vizient may provide any assistance as you consider these recommendations.
Respectfully submitted,
Shoshana Krilow
Senior Vice President of Public Policy and Government Relations
Vizient, Inc.
Submitted by pross@jointcom… on
USCDI Draft v6
On behalf of The Joint Commission, please see the attached comments.
2025_04_14_The Joint Commissions Comments_ASTP_USCDI draft v6.pdf