ONC should clarify how it intends for the two documents to be used by health IT developers. For example, it should clarify how the data element list and their referenced FHIR specifications would translate to potential new functional requirements in the certification program.
The Data Element List that ONC has assembled includes a broader set of data elements and concepts than those used by the current set of eCQMs. ONC should focus on including only data elements actively in use by eCQMs (or in the future, active digital quality measures). Including data elements beyond those required to calculate eCQMs leads to ambiguity in the data element’s intended use—making it more difficult for developers to determine the workflows required to consistently capture and report the data element as part of a quality measure.
ONC should clarify its process for identifying which data elements it will include in the USCDI+ for Quality data element list. Not all of the data elements in its draft list are used in eCQMs today. First, ONC should determine its priority order for transitioning quality measures to use FHIR-based specifications. Then, for each quality measure that it will convert to a FHIR-based specification, ONC should identify the minimum set of data elements that are needed for that quality measure and ensure that mature FHIR implementation guides represent that data element. Finally, ONC should validate that the FHIR representation of the data element includes support for the necessary terminologies and metadata needed to complete the calculation of a quality measure outcome. ONC should work with the standards development community and measure authors/stewards as needed to drive consensus-based updates to FHIR or quality measure specifications.
ONC and CMS should together identify the set of initial quality measures for transition to FHIR-based specifications based on (1) those that have the greatest number of data elements already supported by mature FHIR specifications, and (2) the quality measures that have the broadest applicability to organizations participating in CMS programs. For example, ONC and CMS could consider prioritizing the transition of the three eCQMs that are used in the MSSP ACO program.