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  1. USCDI+ Quality
  2. USCDIQ-34

Massachusetts Health Data Consortium (MHDC) Comments on USCDI+ for Quality Draft Dataset


    • Icon: Question/Guidance Question/Guidance
    • Resolution: Unresolved
    • Icon: Moderate Moderate
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      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.


      About MHDC

      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).

      About DGC

      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:

      1. 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
      2. Education: helping members understand their regulatory obligations, the data and exchange standards they're expected to use, and modern technology and related processes
      3. 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.

      General Comments

      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.


      Links to USCDI Listings

      Consistent Casing

      Using Plurals for Data Class Names

      Cadence for Updates

      Comments on Guidance Document

      Intended purpose of USCDI+ for Quality and Its Place in the Existing Quality Measures Ecosystem

      Requirements for Comprehensive USCDI+ for Quality Data Exchange

      Relationship between USCDI+ for Quality and QI-Core Implementation Guide

      Relationship between USCDI+ for Quality and Quality Measures/Data Exchange for Quality Measures Implementation Guides

      Relationship between USCDI+ for Quality and Specific dQMs and eCQMs from CMS and NCQA

      ONC Certification Against USCDI+ for Quality

      Level of Data Definition

      Time data elements

      USCDI Versions

      Response to Specific Data Classes and Data Elements and Request for Missing Elements

      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.

      Advance Directives data

      Adverse Events and Allergies/Intolerances

      Birth Information vs Newborn Delivery Information

      Cancer Care

      Care Experience and Outcomes


      Family Health History


      Health Insurance vs Health Insurance Information

      Health Insurance Information data

      Medical Devices and Equipment vs Medical Devices

      Medical Devices data

      Medical Device Type

      Medication Dates

      Medications data

      Birth Weight vs Birthweight

      Birth Information::Gestational Age vs Newborn Delivery Information::Gestational Age at Delivery

      Newborn Delivery Information data

      Patient Demographics vs Patient Demographics/Information

      Birth Sex

      Gender vs Gender Identity

      USCDI version of Race, Ethnicity, and Gender/Gender Identity

      Employment Category

      Patient Demographics data

      Pregnancy Status

      SDOH/Health Concerns

      Referrals data

      Date of Physician-ordered Start of Care (Resumption of Care) data element


      Substance data class

      Substance (Non-Medicine) and Substance (Food) data elements

      Height on Admission (in inches) and Weight on Admission (in pounds) Measure weight consistently according to standard facility practice (e.g., in a.m. after voiding, with shoes off, etc.) data elements

      Weight/Height on Admission vs Body Weight/Body Height

      Vital Signs data

      Additional Data Captured by MHDC Quality Measures Specification Not in USCDI+ for Quality






      Memberships/Patient Demographics


      Specific Observations/Tests

            Unassigned Unassigned
            JaniceMHDC Janice Karin
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