ACP Offers Comments on Most Recent Draft Version of the USCDI

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Proposed additions and modifications incorporate social determinants of health; ACP cautions ONC to ensure EHR vendors do not increase costs for physicians

May 20, 2022 (ACP) — The Office of the National Coordinator for Health Information Technology (ONC) recently suggested changes to the U.S. Core Data for Interoperability version 2 (USCDIv2), and the American College of Physicians applauds some components of the proposed changes but urged decision-makers to keep the needs of physicians and patients in mind.

“ONC defines USCDI as a standardized set of health data classes and constituent data elements for nationwide, interoperable health information exchange,” explained Nadia Daneshvar, ACP health IT policy associate. “A data class is ‘an aggregation of various Data Elements by a common theme or use case,’ while a data element is ‘the most granular level at which a piece of data is exchanged.’”

An example of a data class is Allergies and Intolerances, which includes the data elements Substance (Medication), Substance (Drug Class) and Reaction. Another example is Patient Demographics (which includes the data elements First Name, Last Name and Date of Birth, among others).

In a recent seven-page letter, ACP responded to proposed additions and modifications to the USCDI v2 as laid out in Draft USCDI v3.

ACP is pleased that officials want to capture more data in patients' medical records to help understand the effect of social drivers of health, but it worries about protecting privacy and ensuring physicians are not required to input more information than is needed.

“The primary concern of the College is that many of the proposed new data elements do not have enough -- or in some cases, any -- clinical utility to justify their inclusion in the USCDI and thus patients' medical records,” Daneshvar said. “These unnecessary or low-utility data elements represent increased administrative burden for physicians and their care teams, which is problematic for ACP's major priority of reducing clinician burden.”

In its letter, ACP also notes that “the College wishes to emphasize its view that federal data requirements should not end up being opportunities for [electronic health record (EHR)] vendors to increase subscription fees.”

As Daneshvar noted, ONC cannot explicitly prevent the vendors from raising prices. “But ONC has a certain level of control over EHR vendors' practices,” she explained. “For example, ONC can stipulate and/or outline parameters of behavior for vendors regarding new federal data requirements. The College believes it has a responsibility to advocate for small and solo practice physicians, particularly in terms of burden and costs.”

In addition, ACP believes that additional federal data requirements should be included in regular/scheduled system updates that are part of existing EHR contracts and that vendors should not be allowed to use these requirements as an opportunity to increase subscription fees. Daneshvar adds, “The College supports adopting some of the proposed new data elements and considers them important in caring for patients of all identities, but it is important that new federal data requirements not become an additional source of financial burden for smaller practices.”

ONC plans to release the final USCDI v3 in July 2022, according to Daneshvar. “The USCDI will continuously change and expand over time,” she explained. “Generally, draft versions are issued in January and are followed by a comment period and release of the final USCDI version in July. ONC also launched a USCDI+ initiative in October 2021 to support the development of ‘domain- or program-specific datasets' that serve as ‘extensions' to the USCDI. This initiative will allow for the exchange of datasets beyond the floor established by the USCDI for compliance with specific agency requirements.”

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