Submitted by ubackonja@mitre.org on
PACIO: Add ICF to Functional Status
Recommendation: Add the International Classification of Functioning, Disability and Health (ICF) as an Applicable Vocabulary Standard for Functional Status, enabling standardized representation of functioning, activities, participation, and relevant environmental/contextual factors in addition to existing LOINC-based assessment representation.
Rationale: The PACIO Project Community* recommends the addition of the International Classification of Functioning, Disability and Health (ICF) as an Applicable Vocabulary Standard to the Functional Status data element. The purpose would be to complement, not replace, use of other terminologies such as LOINC and SNOMED CT – ICF fills a specific interoperability gap in USCDI and is already an established federal, international, and HL7 standards ecosystem. USCDI currently has mechanisms for representing conditions and problems, but Functional Status and related health-status information require a vocabulary that describes what a person can do, how health conditions affect activities and participation, and what environmental factors influence functioning. ICF was specifically designed for that purpose and therefore complements, rather than duplicates, disease-oriented vocabularies such as ICD. The proposed ICF addition is a semantic complement to LOINC, rather than a replacement -- LOINC can identify the assessment/observation or instrument; ICF can provide a standardized functional-domain classification for what the observation represents. ICF is not an informal clinical terminology. It is an established, computable classification represented in HL7 Terminology. Its inclusion as an Applicable Vocabulary Standard would therefore build upon an existing standards infrastructure rather than require development of a new vocabulary or exchange mechanism.
- Background: The ICF was created in 2001 to classify functioning domains as a consequence of health conditions, which are not completely captured by any other codeable concept ontology. The ICF ontology allows data to be categorized as mental, cognitive, and functional factors, as well as health concerns in a machine-readable way.
- Clinical utility: Research suggests that the ICF is useful in supporting clinical care related to functioning, cognition, and addressing health concerns, as demonstrated by evidence of its validation in post-acute physiotherapy, usefulness in assessing long-term psychiatric care, and utility in evaluating a telerehabilitation intervention.
Support: The ICF has been recommended or endorsed by The National Committee on Vital and Health Statistics (NCVHS) and the American Physical Therapy Association. The American Speech-Language-Hearing Association (ASHA) provides information on how to use the ICF. CMS and the CDC provide guidance on using the ICF.
Current Standards:
- The ICF was developed to complement ICD, with ICF covering functioning and environmental factors and ICD covering diseases and other health problems. As described by the developing organization, “ICF is based on the same foundation as ICD…and share the same set of extension codes that enable documentation at a higher level of detail.”
- ICF is among the terminologies listed within the International Organization for Standardization (ISO) 14639–2 eHealth Roadmap.
- ICF has been mapped to SNOMED.
- HL7 Terminology v5.0.0 includes an ICF code system.
- HL7 Terminology v7.0.1 includes an ICF naming system.
- The PACIO Project makes extensive use of the ICF ontology in the Personal and Functional Engagement (PFE) FHIR IG STU-2 as category codes for several profiles. STU-3 (currently under ballot) integrates validated mappings between ICF, LOINC, and commonly used PAC measures.
Current Use:
Current integration: Three vendors have deployed the PACIO PFE IG that integrates the ICF: Global Alliant, Open City Labs, and Patient Centric Solutions.
Potential expanded integration:
- CMS requires the collection of functional, mental, and cognitive status data from PAC facilities (e.g., Minimum Data Set for nursing facilities, Inpatient Rehabilitation Facility Patient Assessment Instrument [IRF-PAI]); therefore, all PAC vendors have the potential to apply ICF to the volume of Functional Status and Mental/Cognitive Status data already collected.
- The VA and VHA have integrated the ICF into several of their data-gathering activities. One is the Rehabilitation Research Development and Translation Broad Portfolio (RRDT), which is “[g]rounded in the International Classification of Functioning, Disability and Health (ICF).” The other is the Traumatic Brain Injury (TBI) Registry software, which integrates various assessments including WHODAS 2.0, which is based on the ICF and has a “direct conceptual link” to the ICF. Therefore, integrating the ICF as an applicable vocabulary would support the VA and VHA’s efforts to collect standardized functioning data from Veterans.
Current Exchange:
Active Exchange: The ICD-API includes the ICF as a CodeSystem in FHIR.
Recent demonstration:
- During 2026 ICD-11 FHIR Connectathons, implementers exercised ICD-11 and ICF through the WHO FHIR terminology service, including terminology lookup, validation, search, and expansion operations.
The ICF-integrated PACIO PFE IG has been used to successfully exchange ICF-coded data during the July 2025 CMS Connectathon, when ICF was applied to the PHQ-9 assessment, as well as the January 2026 HL7 Connectathon and July 2027 CMS Connectathon, when ICF was applied to PROMIS-10 measures.
Potential expanded integration: Information that can be captured by the ICF is currently being exchanged by FindHelp, which has a closed-loop referral service that exchanges back and forth supporting social needs information between organizations. FindHelp demonstrated social needs data exchange with other vendors during the Gravity Track of the July CMS Connectathon. Social needs are captured in ICF’s section e, making ICF immediately applicable to FindHelp.
* The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, which aims to advance interoperable health information exchange between post-acute care (PAC) providers, patients, and other key stakeholders across health care.







Submitted by ubackonja@mitre.org on
PACIO: Include FCMs in Functional & Mental/Cognitive Status
Recommendation: Expand the definitions of Functional Status data element to include the American Speech-Language-Hearing Association (ASHA) Functional Communication Measures (FCMs) that have assigned LOINC codes. Functional communication data are already standardized and electronically collectible and should be clearly recognized within USCDI so that they can participate in the federal interoperability infrastructure being implemented by ONC.
Rationale: The PACIO Project Community* recommends including Functional Communication Measures (FCMs), in the definitions of the Functional Status data element to demonstrate the capability in each of these domains for capturing communication-specific health information. FCMs address functional communication in real-world contexts, rather than simply documenting a diagnosis such as aphasia or a generic cognitive impairment. Therefore, inclusion of FCMs would help support patient- and caregiver-centered care as well as patient engagement. Also, adding FCMs to the definitions of Functional Status and Mental/Cognitive Status would make clinically meaningful communication-function information more readily recognizable as part of the standardized health information that should be available for interoperable exchange, rather than leaving it dependent on local implementation choices or narrative documentation.
Current Standards:
Background: FCMs were created by the American Speech-Language-Hearing Association (ASHA) and are “used to describe an individual’s functional abilities over the course of speech-language pathology intervention in a given level of care,” according to an ASHA user guide. Eight FCMs have been endorsed by NQF for use in the Physician Quality Reporting System, including: Attention, Memory, Motor Speech, Reading, Spoken Language Comprehension, Spoken Language Expression, Swallowing, and Writing. Of note, an NQF-endorsed measure “tends to be one that is generally regarded as a high-quality measure” by CMS.
Practice: FCMs have been designed to support compliance with CMS requirements to “report all outcomes data on all Medicare Part B beneficiaries receiving speech-language services” (ASHA). In 2007, CMS recommended use of the NOMS, which includes FCMs, by speech-language pathologists.
Technical: Existing technically mature standards already capture functional communication data that cover a large portion of speech-language pathology (SLP) practice. LOINC includes FCM items, organized within a swallowing panel (99852-6), cognition panel (99788-2), Multi-Modal Functional Communication panel (99828-6), Spoken Language Comprehension panel (99836-9), and Spoken Language Expression panel (99844-3). These LOINC codes assigned to FCMs represent the collaboration between SLPs and other disciplines
Regulations:
Current Use:
Current Exchange:
Breadth of Applicability:
Applicable Standards:
* The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, which aims to advance interoperable health information exchange between post-acute care (PAC) providers, patients, and other key stakeholders across health care.