We have submitted comments on the Office of the National Coordinator for Health Information Technology’s (ONC) United States Core Data for Interoperability Plus (USCDI+) Quality Draft V2 Data Element List, which is intended to support quality measurement and health data interoperability.
Our recommendations:
- Use a transparent regulatory process, with opportunities for stakeholder input before new data elements are added, rather than relying on a sub regulatory process for such a significant framework.
- Provide greater clarity on how USCDI+ Quality will be used in quality measurement programs, how it complements existing and emerging approaches such as FHIR-based digital quality measures, and why a separate framework is needed.
We also urged ONC to align laboratory data standards across USCDI and USCDI+ Quality, identified discrepancies in several laboratory data elements, and raised concerns about a proposed standard that may not be appropriate for specimen information.
Bottom line: We support efforts to improve interoperability and quality measurement but emphasized that changes to data standards should be transparent, well-justified, and developed with meaningful stakeholder input.