On behalf of the American Society for Radiation Oncology (ASTRO), I am writing to thank the Office of the National Coordinator for Health Information Technology (ONC) for issuing a draft data element list for USCDI+ Quality. ASTRO is the largest radiation oncology society in the world, with more than 10,000 members who specialize in treating patients with radiation therapies. As the leading organization in radiation oncology, biology and physics, the Society is dedicated to improving patient care through education, clinical practice, advancement of science and advocacy. ASTRO’s highest priority has always been ensuring patients receive the safest, most effective treatments. We applaud the proposal to develop a predictable, transparent process for organizing data elements that supports the exchange and use of data for quality measurement across programs, payers, and care settings.

Specifically, ASTRO would like to thank ONC for including the mCODE radiation therapy-related data elements.  Approximately 50% of people with cancer will receive radiation therapy during their course of treatment and having the ability to document and measure the quality of their treatment in a standardized manner will be invaluable. ASTRO, alongside the American Association for Physicists in Medicine (AAPM), the Canadian Association of Radiation Oncology, the European Society for Therapeutic Radiology and Oncology, and other groups have worked together under the CodeX FHIR Accelerator to create the mCODE radiation therapy standards to break down siloed cancer data. Care coordination, comparison of treatment regimens, quality and research all improve with the presence and use of data standards, and ASTRO is already working on using mCODE for quality measures within the CodeX initiative. We believe inclusion of the mCODE value sets will provide a greater level of detail for our patients and providers, and we support the inclusion of the data elements in the USCDI+ proposal.

We are particularly pleased with the inclusions of “Radiotherapy Course Summary” and “Radiotherapy Volume.” Including these two value sets in USCDI+ will ensure a unified capture of treatment data, which can be used for expanded quality reporting for the field of radiation oncology.  Of note, the Center for Medicare and Medicaid Innovation (CMMI) proposed the inclusion of data element collection to potentially use for quality measure development in the proposed Radiation Oncology Alternative Payment Model (RO-Model). The model was never finalized, in part because of significant concerns regarding model requirements for quality measures, data capture, and reporting. In particular, the RO model lacked standardization of nomenclature, data elements and implementation in vendor systems.

As ASTRO stated in our 2020 comment letter on the RO Model RFI: “Unstandardized data will increase the burden of data collection, exasperate issues with data transfer and result in a repository of data that is of little use.” In the three years since that comment, ASTRO, together with AAPM, have worked diligently on the mCODE Standard which now enables standardized data that could be of high value. We were pleased to see the inclusion of mCODE reporting as an option for the upcoming Enhancing Oncology Model and hope that the inclusion of the radiation therapy value sets in USCDI+ could have the same positive outcome in future radiation therapy models and other quality outlets.

Development for radiation therapy standards goes beyond what is included in mCODE, in the adjacent HL7 Radiation Therapy Implementation Guide and in the broader recent publication of the Operational Ontology for Oncology (O3), and we look forward to when more detailed radiation therapy data can be collected in a standardized manner. This initial inclusion of radiation therapy-related data will allow standardization of the reporting of radiation therapy data elements, and we encourage the ONC to finalize the draft.

We appreciate the opportunity to provide comments on the draft USCDI+ Quality data elements and look forward to continuing to work with ONC on these and future issues. If you have any questions, please contact Randi Kudner, Assistant Director of Quality Improvement at Randi.kudner@astro.org or 703-286-1664.