On April 18, 2018 the HHS Health Information Technology Advisory Committee (HITAC) US Core Data for Interoperability Task Force delivered its recommendations on the draft US Core Data for Interoperability (USCDI) and Proposed Expansion Process which had been published for public comment back in January 2018. HITAC promptly accepted the Task Force’s recommendations.
The Task Force focused almost exclusively on the process for identifying the USCDI rather than the proposed USCDI data itself. I especially appreciated their introduction of some key concepts related to how USCDI should be organized and understood. It has always bothered me that the current Common Clinical Data Set (CCDS) upon which the current draft USCDI is based contains a variety of types of data at different levels of analysis: for instance, a single discreet data element (like date of birth or sex) sits alongside more complex data constructs (like address, which contains many discreet data elements within it) which sit alongside even more complex data types (like immunizations or procedures). The Task Force introduces a notion of hierarchy to make this more sensible: data classes (high level topic like “demographics”), data objects (a single item within a class, like “address” within the class “demographics”), and data object attributes (a specific data element within a data object, like “zip code” within “address”).
From a process standpoint, the Task Force recommended an expanded set of steps which has an emphasis on more stakeholder participation and less ONC pronouncement. This includes a recommendation for patient input as well. These are welcomed additions and I certainly hope they will be operationalized by ONC.
On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program based on our earlier comments:
