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.

Definitions

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

Communications

Family Health History

Goals

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

Screenings

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

Diagnoses/Problems

Exceptions

Immunizations

LaboratoryServices/Laboratory

Medications

Memberships/Patient Demographics

Procedures

Specific Observations/Tests