The American Hospital Association Urges Clarity and Alignment in USCDI Data Standards

On April 13, the American Hospital Association (AHA) submitted comments to the Department of Health and Human Services (HHS) regarding the U.S. Core Data for Interoperability Draft Version 7, a standardized collection of data elements designed to facilitate nationwide interoperable electronic data sharing. The elements are part of the Health IT Certification Program by the Office of the National Coordinator for Health IT (ONC).

“While we support several of ONC’s proposals, other proposed changes lack clarity of purpose, do not align well with clinical workflows and would inadvertently run counter to the USCDI goals by increasing burden, reducing reliability and exacerbating unwarranted variation,” the AHA wrote in a letter to Thomas Keane, M.D., MBA, National Coordinator for Health Information Technology.

The AHA suggested that ONC incorporate specific USCDI data elements that align with clinical workflows and are supported by certified health IT, including device type, accommodation, and deceased indicators.

Additionally, the AHA advised ONC to avoid adopting proposed USCDI data elements that conflict with current processes and pose greater risks than benefits, such as adverse events and referral notes. “We are concerned that the proposed new “adverse events” data class does not have clear definitions, does not reflect existing clinical workflows and may be inconsistent with existing federal regulatory frameworks governing information sharing for adverse events,” the AHA stated.

Lastly, the AHA urged ONC to issue clear guidance and establish vocabulary standards before adopting USCDI data elements like patient identifier, diagnostic imaging reference, nutrition assessment, reason not performed, and health insurance information. 

“We look forward to working with the agency to refine USCDI v7 proposals and further advance data interoperability to support patient care,” the AHA expressed.