Thank you for the opportunity to submit feedback around the proposed USCDI+ Quality Data Element List. 

Level of Completeness:

• To what extent does the data element list contain a comprehensive list of data elements relevant to measuring quality for important health processes and outcomes?
  • It is difficult to comment on this without more clarification about the intent of the USCDI+ Quality Data Element list. Some of the proposed data elements are not cross walked to specific eCQMs on the Use Case Mapping table, and we would appreciate further clarification on the intended use cases of these (e.g. Advanced Directives, Care Experience and Outcomes). Otherwise, the data element list seems very comprehensive for existing eCQMs but seems overly broad.
• Are there additional data classes and/or elements ONC should consider for inclusion?
  • N/A, existing eCQM elements + proposed elements are inclusive enough

Level of Specificity:

• Are the data classes and data elements list in sufficient detail to result in adoption in electronic systems that would make data available for use in quality measures?
  • It seems like some of this is more detail than what is currently needed for many of the eCQM data elements. For example, CMS-347 looks to the Adverse Event of “Statin Allergen” as a denominator exclusion. There is a request to add “suspect entity” and “recorded” information (which is not currently documented discretely) that doesn’t appear to have an impact on that exclusion. Does this imply that organizations would have to start documenting each of these data elements discretely and thus the EHR vendors would need to prioritize resources to building out that functionality when it doesn’t have a strong impact on the measure itself?
• Does the data element list provide clear guidance about data priorities that would incentivize capture of data elements relevant to quality measurement within electronic systems?
  • No, it does not seem to expand upon the use cases of these elements with enough specificity that organizations understand what is expected of them – is the requirement that every noted element becomes discretely documented and then linked with a FHIR API to pull for dQMs? If so, that is a tremendous amount of work to not only build the APIs but also for EHR vendors to release functionality to document the new data discretely. This is slightly easier to understand for data elements linked to specific eCQMs, but still more guidance would be necessary for prioritization.

Usefulness of Companion Guidance:

• How useful is the crosswalk to individuals who develop and implement measures and FHIR IGs?
  • There is some level of usefulness in the crosswalk for data elements with a clear purpose that map to existing eCQMs, but there are many elements that are on the list that don’t map to any eCQMs (e.g. Advance Directives), and on the list itself those that do map aren’t mapped to a specific value set to understand how these would align with existing workflows.
• What companion guidance about the relationship between data classes and data elements, and their potential expression in FHIR would be useful in future publications?
  • Additional use cases for how these data elements would be documented locally, then expressed in FHIR, then used to calculate eCQM numbers would be helpful.

Frequency of Updates:

• USCDI standard updates usually occur annually. One goal of USCDI+ is to help stakeholders with tailored needs to establish standardized data sets in a more flexible manner. What frequency of updates to USCDI+ Quality would be useful for achieving this objective?
  • Annual seems appropriate as that’s the frequency of updates to the eCQM specifications themselves.