See Below is a copy of Vanessa Holley’s Comments overall comments on the USCDI+ Platform under Public Health Use Case. In addition, Vanessa commented on individual data elements. APHL’s comments on individual data elements are collected in a spreadsheet:
| View file | ||
|---|---|---|
|
Overall Comments
The Association of Public Health Laboratories (APHL) thanks ONC for the opportunity to comment on USCDI+. We have submitted several specific comments, but also wanted to comment on the overall philosophy of USCDI+
We believe the mission of USCDI is clear. Healthcare Organizations (HCOs) and Electronic Health Records (EHRs) that are addressed by current, relevant Federal regulation(s) are required to have Health Information Technology (HIT) products that can exchange the USCDI data. USCDI does not obligate the HCOs and EHRs to produce the data in these formats, but they must be able to support these for data exchange purposes. While USCDI certification does not currently affect other HIT systems in the healthcare ecosystem that interact with HCO and EHR and may therefore not implement to USCDI standards, setting an expectation with clear definitions for all to eventually use as a baseline is invaluable.
USCDI+, however, is not required of HCOs / EHRs by regulation and its purpose has been less clearly articulated. We believe that possible purpose(s) ONC may be contemplating could include:
...