AHIP appreciates the Office of the National Coordinator for Health Information Technology's (ONC) ongoing work to advance the interoperability of health information through the United States Core Data for Interoperability (USCDI). We agree that a common set of data classes and elements is essential to achieving interoperability and support ONC's work to create the USCDI+ Quality to facilitate the exchange of data to support performance measurement and adverse event reporting.  We appreciate ONC leading this work and encourage the agency to collaborate with the private sector when developing USCDI+ modules and to add data elements to the base USCDI as appropriate to support interoperability across the health care system.

Level of Completeness

First, we appreciate ONC's efforts to coordinate with the Core Quality Measures Collaborative (CQMC) and build on the CQMC's work when developing the USCDI+ Quality.  Aligned measures based on interoperable data has the potential to reduce the burden on clinicians and providers while providing all stakeholders more robust information on performance. We strongly encourage ONC to continue to collaborate with the CQMC when updating the USCDI+ Quality in the future and prioritize the data elements necessary to calculate the CQMC core measures for future versions.

We also urge ONC to include data elements for high-value measures beyond CMS programs.  For example, ONC should add data elements to support the exchange of data to support the National Committee for Quality Assurance (NCQA)'s HEDIS measures to support aligned measures across public and private payers.  ONC should also prioritize high-value but high burden measures such as patient experience measures, patient-reported outcomes-based performance measures (PRO-PMs), and social needs screening measures where digital measurement could materially advance their use and facilitate the exchange of person-centered data.  Promoting the interoperability of patient-generated data could allow for it to be used across the system while reducing the response burden on patients.

Level of Specificity

As ONC considers the data elements to include, we urge the agency to ensure USCDI+ Quality data elements are feasible and can be consistently captured and shared. Data elements included in the USCDI+ Quality should be available to share in an interoperable, understandable format. ONC should not add data elements that do not have associated standards that are sufficiently tested and mature. AHIP supports a deliberate yet incremental approach to the expansion of the included data elements. A balance must be achieved between the addition of data fields, especially in areas that are not yet well defined through standardized terminology, and a recognition of the need to minimize burden on front line providers.