The comment below is also being submitted as an attachment. Please note that we tried to include the full text directly in the body of the Jira ticket but the text was too long. After some basic metadata, we decided the best way to handle this was to provide a sort of Table of Contents in the main ticket body by presenting all of the section headings.
Please see the attachment for our full comments.
Founded in 1978, MHDC, a not-for-profit corporation, convenes the Massachusetts’s health information community in advancing multi-stakeholder health data collaborations. MHDC’s members include payers, providers, industry associations, state and federal agencies, technology and services companies, and consumers. The Consortium is the oldest organization of its kind in the country.
MHDC provides a variety of services to its members including educational and networking opportunities, analytics services on both the administrative and clinical side (Spotlight), and data governance and standardization efforts for both clinical and administrative data (the Data Governance Collaborative/DGC and the New England Healthcare Exchange Network, respectively).
The DGC is a collaboration between payer and provider organizations convened to discuss, design, and implement data sharing and interoperability among payers, providers, patients/members, and other interested parties who need health data. It is a one stop interoperability resource. The DGC primarily focuses on three areas:
- Collaboration: Development of common understanding of and specifications for data standards, exchange mechanisms, and what it means to participate in the modern health IT ecosystem
- Education: helping members understand their regulatory obligations, the data and exchange standards they're expected to use, and modern technology and related processes
- Innovation: Identification and development of projects and services needed to make modern health data practices and exchange a reality
Particularly pertinent to this comment is the DGC history working on quality measures. The first major project of the DGC involved creating a (pre-FHIR) flat file data exchange using Secure FTP to send data between payers and providers. This specification – called the MHDC Quality Measures specification - was developed collaboratively in conjunction with payers and providers in Massachusetts, was first released on December 31, 2019, and is still in use.
This section includes general comments on the approach and data included in the USCDI+ for Quality dataset and its place in the quality measures ecosystem.
Relationship between USCDI+ for Quality and Quality Measures/Data Exchange for Quality Measures Implementation Guides
This section will address specific data classes and data elements in the USCDI+ for Quality proposal and comment on potentially missing data. We are including a section outlining data we collect for our MHDC Quality Measures specification not included in USCDI+ for Quality. In general, we chose not to separately list those data elements in the more general comments about the same data elements.