Health Status Assessments

ASHA: Disability Status and Disability Assessment

ASHA is the national professional, scientific, and credentialing association for 247,000 members, certificate holders, and affiliates who are audiologists; speech-language pathologists (SLPs); speech, language, and hearing scientists; audiology and speech-language pathology assistants; and students. Audiologists specialize in preventing and assessing hearing and balance disorders as well as providing audiologic treatment, including hearing aids. SLPs identify, assess, and treat speech, language, swallowing, and cognitive communication disorders. The American Speech-Language-Hearing Association (ASHA), supports the PACIO Project recommendations to the Office of the National Coordinator for Health Information Technology (ONC) to: 

1. Rename the existing "Disability Status" data element under the Health Status Assessments data class to "Disability Assessment" and provide a refined definition and updated examples for the data element.
2. Add a Disability Status data element under the Patient Demographics/Information data class, consistent with the HHS Data Council’s own Implementation Guidance and with the intent of Section 4302 of the Affordable Care Act (ACA). 

 Together, these recommendations address a critical issue in the current structure, which conflates clinician-documented evaluation with patient-reported information and identity, including communication-related disability and access needs, contributing to inconsistency in documentation and its use.  

Renaming the existing element to “Disability Assessment” more accurately reflects its function as a clinical evaluation of health status and supports more consistent and appropriate use within care planning and documentation workflows. This is particularly relevant for people with communication-related disabilities, where clinical assessment informs care planning but does not replace patient-reported needs related to communication access. This distinction is necessary for maintaining data integrity and ensuring that assessment data do not serve as proxy for patient-reported demographic information.    

Placement of Disability Status within Demographics is necessary to ensure consistent, longitudinal data capture across encounters, providers, and health systems. In contrast to assessment data, which are often episodic and context-dependent, demographic data elements are more reliably exchanged through interoperable systems, including consistent identification of communication access needs across care settings. They are better positioned to support care coordination, population health measurement, and quality reporting.  

In addition, aligning Disability Status with the corresponding Accommodations data element within the Demographics data class enhances the operational utility of the data. Structuring both elements at the demographic level enables standardized identification and transmission of accommodation needs across workflows, including intake, triage, and care delivery, and supports implementation through clinical decision support tools, flags, and other health IT functionalities.  This is particularly important for people with communication disorders and differences, where timely access to appropriate supports is foundational to safe and effective care.  

Collectively, these updates will facilitate more reliable data exchange, reduce variability in documentation practices, and enable more robust analysis of disparities in access, care process, and outcomes for people with disabilities. These changes represent advancements in interoperability, continuity of care, and patient-centered health care delivery.  

Disability Status as a Demographic

The Disability Equity Collaborative (DEC) is a community of engaged stakeholders — including disability advocates, researchers, healthcare organizations, and others committed to improving disability access in healthcare. We write today to urge the Office of the National Coordinator for Health Information Technology (ONC) to adopt the recommendations of the PACIO Project, which we believe are essential to ensuring that disability data is captured accurately and meaningfully within the United States Core Data for Interoperability (USCDI):

1. Rename the existing "Disability Status" data element under the Health Status Assessments data class to "Disability Assessment," accompanied by a refined definition and updated examples.
2. Add a new Disability Status data element under the Patient Demographics/Information data class, consistent with the HHS Data Council's own Implementation Guidance and with the intent of Section 4302 of the Affordable Care Act (ACA).

We cannot overstate the importance of this distinction. As it stands, the current structure conflates two fundamentally different concepts — and the consequences for people with disabilities are real.

Disability Status is not assessed — it is a patient-reported demographic. Disability Status questionnaires, like the American Community Survey (ACS) questions, are survey instruments designed to identify people with disabilities. In the healthcare setting, this information serves critical purposes: it drives quality improvement efforts and determines whether a patient is entitled to reasonable accommodations under the Americans with Disabilities Act. These questions are not typically administered by clinicians and are not used to evaluate functioning. They belong where all demographic data belongs — under Patient Demographics/Information.

Disability Assessment, by contrast, refers to clinician-administered evaluations using validated health assessment tools such as the VR-12 and PROMIS. These instruments measure health outcomes across multiple domains that contribute to a person's quality of life. They evaluate a patient's functioning and impairment and are essential for providers developing treatment or care plans specifically related to that impairment.

We urge ASTP/ONC to recognize that disability status and clinical impairment are not interchangeable. A person's disability status is not necessarily reflective of their clinical diagnosis. As the International Classification of Functioning makes clear, disability is the intersection of a person's impairment and the external factors in their environment. Health assessment tools like the VR-12 and PROMIS measure impairment — they do not and cannot determine disability status. There is no reliable method to derive a patient's disability status from diagnostic codes or assessment instruments. It must be recorded as a patient-reported demographic.

Without this change, we risk perpetuating a data infrastructure that obscures the needs of people with disabilities rather than illuminating them. We respectfully but firmly call on ONC to act on these recommendations and ensure that USCDI reflects the lived reality of the disability community.

Sincerely,

Recommend unique Disability Status demographic data element

Independent capture of Disability Status as a Patient Demographic in the United States Core Data for Interoperability (USCDI), separated from rather than included along with disability assessments, is a foundational step toward equal health treatment for the more than one in four American adults who report living with a disability. Based on the consensus of the PACIO Disability Status Work Group — comprising clinicians, EHR vendors, health systems, disability advocates, and federal agency participants — the PACIO Community respectfully urges the Assistant Secretary for Technology Policy (ASTP) to: 

1.  Rename the existing "Disability Status" data element under the Health Status Assessments data class to "Disability Assessment" and provide a refined definition and updated examples for the data element.
2. Add a Disability Status data element under the Patient Demographics/Information data class, consistent with the HHS Data Council’s own Implementation Guidance and with the intent of Section 4302 of the Affordable Care Act (ACA). A corresponding ONDEC submission is forthcoming.

These recommendations aim to disambiguate between demographic and clinical uses of disability-related data by clarifying that (1) the Health Status Assessments element captures clinician-collected health assessment data and (2) the new Patient Demographics/Information element captures self-reported disability status as a demographic characteristic.

The attachment to this comment documents the benefits that proper capture of “Disability Status” as a demographic will enable: closing persistent gaps in health surveillance, unlocking cross-system interoperability for demographics across federal agencies and post-acute care settings, reducing conflation of demographics with clinical assessment, and advancing patient autonomy. It also addresses the functional framing of the American Community Survey six-question set (ACS-6) on disability and demonstrates that this framing is immaterial to its classification as a demographic data element.

For the complete rationale, three-domain framework synopsis, and supporting references, please see the attached document.

PACIO_USCDI_V7_Comment_Disability_Status_v2.5_0.pdf

The following are comments from multiple health systems representatives within the Disability Equity Collaborative's Leaders Learning Collaborative:

1. Disability status as a demographic and associated accommodations data needs to be captured

“Capturing disability status—as a demographic—and linked accommodations data is essential for providing equitable, person-centered care. Disability is a protected class under federal nondiscrimination laws (ADA, Section 504, HHS Section 1557 Final Rule). Without systematically capturing this information, organizations cannot identify disparities, ensure accessibility, proactively meet accommodation needs, or comply with legal and regulatory mandates.” 

“Capturing disability as a demographic ensures that it is respected and treated with the same importance, and permanence, as age, sex, race, language, etc. It enables quick, convenient, and universal visibility across care providers: registration, scheduling, transfer, patient experience, etc. No one has to “dig in the chart” to find this information. It supports timely delivery of aids and services when coupled with the appropriate accommodation need (e.g., deaf with ASL interpreter; blind with qualified readers, etc.).

“Treating [disability status] as a demographic helps us understand our patient population and address equity gaps…We can’t assume these needs based on diagnoses.”

“Having a standardized method for capturing disability status and accommodation needs supports clinicians and the broader care team—particularly support staff who frequently communicate essential information to patients. Standardized documentation ensures that disability-related needs are consistently recognized, respected, and integrated into every stage of the care experience.”

Example

“A patient who is Deaf and uses ASL marks “Deaf/Hard of Hearing” in their demographic disability field and selects “ASL interpreter” under accommodations. This information automatically flows to scheduling, the visit record, and interpreter services, ensuring an ASL interpreter is booked before every appointment, preventing last-minute scrambling and ensuring legal compliance.”

2. How disability status is currently or is planned to be used:

• Clinical Care: Alerts clinicians and care teams so they can prepare accessible equipment (e.g., height-adjustable exam table), communication tools (e.g., interpreter, communication board), and care modifications.
• Operational Planning: Helps organizations forecast demand for accessible equipment, sensory-friendly environments, or specific communication supports.
• Quality & Safety: Allows monitoring of missed appointments, long wait times, or adverse events among patients with disabilities to identify disparities.
• Digital Accessibility: Ensures patient portal, telehealth, and digital communications are usable for those with screen readers, cognitive needs, or low vision.
• Research & Equity Analytics: Supports disability-inclusive research design
• Emergency Preparedness: Enables identification of patients needing assistance during evacuation or emergency communications.
• Human Resources & Workforce Inclusion: When used for employees, supports accommodation planning, workspace accessibility, and trend analysis.”

“Demographic data, including disability status and accommodation needs, is routinely shared with an individual’s health plan, specialty providers, and partnering services such as home health and rehabilitation. Ensuring that all participating providers and organizations have access to this critical information strengthens care coordination, supports continuity, and enables timely planning for appropriate accommodations. Ultimately, this improves the safety, accessibility, and effectiveness of the care delivered across settings.”

“We use this data to make sure the right supports are in place before a visit and throughout a patient’s care. This includes scheduling, communication preferences, equipment needs, care-team awareness, and coordinating services like interpreters. It also helps with broader work—quality improvement, health equity efforts, and planning for resources across the system.” 

Example

“After collecting disability demographic data, the Quality & Safety office finds that patients with mobility disabilities experience lower rates of cancer screening due to inaccessible equipment. This triggers a systemwide initiative to purchase height-adjustable tables and wheelchair-accessible mammography equipment.”

3. What needs are satisfied if/when your organization documents this information

A. Patient Needs-Ensures care is accessible, safe, and respectful. Reduces the burden on patients to repeatedly explain their disability or accommodation requirements. Improves satisfaction, trust, and overall patient experience. Enables proactive planning (e.g., longer appointment times, accessible transport instructions).

B. Provider & Staff Needs-Reduces uncertainty by providing clear information before the visit. Improves efficiency by avoiding last-minute problem-solving. Enhances staff confidence in delivering equitable, compliant care.

C. Organizational Needs-Supports compliance with ADA, Section 504, HHS Final Rule, Joint Commission, and CMS requirements. Enables systemwide reporting and performance improvement. Strengthens readiness for legal audits or disability-related complaints. Demonstrates commitment to health equity and inclusive care.

D. Systemwide Equity & Research Needs-Ensures people with disabilities are included in research in ethical, accessible ways.”

“This information allows us to understand the specific needs of the patient population we serve and the accommodations necessary for patients to fully access care. It can also be used to guide targeted disability-competency training for clinicians and support staff—training that is essential for building clinical confidence and addressing the negative behaviors or attitudes that patients with disabilities too often encounter…”

“…from a system standpoint, it allows us to track outcomes, understand disparities, and make sure accommodations follow patients across settings so they don’t have to repeat their needs over and over.”

“Documenting disability status and related accommodation needs allows healthcare organizations to deliver the right aid to the right person at the right time; provide history of patient needs and preferences (VRI vs. in person interpretation, etc.); anticipate and prepare for the needs of repeat patients; collect data for quality improvement initiatives; and ensure consistency and reliability across the healthcare system (doctor clinic, hospital, imaging center, etc.)”

Advancing Disability Status and Accommodation Elements

Disability Rights Education and Defense Fund (DREDF) is a national cross-disability law and policy center that protects and advances the civil and human rights of people with disabilities through legal advocacy, training, education, and development of legislation and public policy. We are committed to increasing accessible and equally effective healthcare and opportunities for people with disabilities so they can lead full, productive lives in the communities of their choice.

We submit this comment to strongly support recommendations made by the Post-Acute Care InterOperability (PACIO) Project to reclassify Disability Status from its current classification under the US Core Data for Interoperability (USCDI) as an element of Health Status Assessments to classification as an element of Demographic Identification. In doing so, we are not claiming that disability status is irrelevant for health status. Rather, we assert that disability status is far more relevant to demographic and social identity, in the same way that race/ethnicity, gender, income, and other personal characteristics are recognized as demographic elements. The functional disability questions for disability status do not have a one-to-one relationship with precise clinical measurements, and they also cannot be directly mapped onto binary models such as healthy/unhealthy or well/unwell. Rather, the true value of the disability status questions lies in how they enable people with disabilities to recognize themselves and thereby count as subjects of needed research, individual patients who need accommodations and policy modifications to receive effective healthcare, and persons who experience multiple health-related barriers.

As DREDF has detailed in a 2024 brief on demographic disability data, such data is necessary to obtain:

• Granular research that will further unearth ongoing health inequities that are not attributable to clinical explanation, and that will aid law and policy makers to address the barriers and gaps in education, knowledge, and systems that lie behind disability-related healthcare disparities
• Disability identification that will trigger data and IT systems to obtain information needed for an accommodations data element that could finally enable people with various disabilities to receive equally effective healthcare;
• Research that can examine how disability interacts with other demographic factors and within/among subpopulations, allowing us to gain a fuller understanding of individuals can experience compounded barriers to health and healthcare

For similar reasons, we also strongly endorse the advancement of the Accommodation data element to at least Level 2, as recommended by Centers for Disease Control (CDC) and the Centers for Medicare and Medicaid - Center for Clinical Standards and Quality (CMS-CCSQ) in their submitted comments.

As identified in many of the comments submitted in support of the PACIO Disability Status and Accommodations recommendations, the disability community is finally seeing movement in the healthcare system to acknowledging disability status as a demographic element. Electronic health record vendors such as EPIC Systems are finally recognizing how health record keeping affects people with disabilities, health plans and clinics are developing ways to keep and use accommodations data, there are efforts at state and county levels to accurately gather demographic disability data. USCDI should be at the forefront of these efforts, helping to ensure consistency of, and guidance on, necessary disability data characterization.

As an organization is run by and for people with disabilities, DREDF calls for the adoption of the PACIO recommendations as a step that will help further advance the federal demographic data collection standards implemented by the federal Department of Health and Human Services almost 14 years ago.

Submitted by Silvia Yee, Policy Director, Disability Rights Education and Defense Fund (DREDF)

Advancing Disability Status and Accommodation Elements

Disability Rights Education and Defense Fund (DREDF) is a national cross-disability law and policy center that protects and advances the civil and human rights of people with disabilities through legal advocacy, training, education, and development of legislation and public policy. We are committed to increasing accessible and equally effective healthcare and opportunities for people with disabilities so they can lead full, productive lives in the communities of their choice. 

We submit this comment to strongly support recommendations made by the Post-Acute Care InterOperability (PACIO) Project to reclassify Disability Status from its current classification under the US Core Data for Interoperability (USCDI) as an element of Health Status Assessments to classification as an element of Demographic Identification. In doing so, we are not claiming that disability status is irrelevant for health status. Rather, we assert that disability status is far more relevant to demographic and social identity, in the same way that race/ethnicity, gender, income, and other personal characteristics are recognized as demographic elements. The functional disability questions for disability status do not have a one-to-one relationship with precise clinical measurements, and they also cannot be directly mapped onto binary models such as healthy/unhealthy or well/unwell. Rather, the true value of the disability status questions lies in how they enable people with disabilities to recognize themselves and thereby count as subjects of needed research, individual patients who need accommodations and policy modifications to receive effective healthcare, and persons who experience multiple health-related barriers.

As DREDF has detailed in a 2024 brief on demographic disability data, such data is necessary to obtain:

• Granular research that will further unearth ongoing health inequities that are not attributable to clinical explanation, and that will aid law and policy makers to address the barriers and gaps in education, knowledge, and systems that lie behind disability-related healthcare disparities
• Disability identification that will trigger data and IT systems to obtain information needed for an accommodations data element that could finally enable people with various disabilities to receive equally effective healthcare;
• Research that can examine how disability interacts with other demographic factors and within/among subpopulations, allowing us to gain a fuller understanding of individuals can experience compounded barriers to health and healthcare

For similar reasons, we also strongly endorse the advancement of the Accommodation data element to at least Level 2, as recommended by Centers for Disease Control (CDC) and the Centers for Medicare and Medicaid - Center for Clinical Standards and Quality (CMS-CCSQ) in their submitted comments. When people with disabilities are consistently asked about the healthcare accommodations and policy modifications that they need, and when that information is consistently recorded and used, we will be that much closer to achieving health, choice, and independence as individuals and as a community.

As identified in many of the comments submitted in support of the PACIO Disability Status and Accommodations recommendations, the disability community is finally seeing movement in the healthcare system to acknowledging disability status as a demographic element. Electronic health record vendors such as EPIC Systems are finally recognizing how health record keeping affects people with disabilities, health plans and clinics are developing ways to keep and use accommodations data, there are efforts at state and county levels to accurately gather demographic disability data. USCDI should be at the forefront of these efforts, helping to ensure consistency of, and guidance on, necessary disability data characterization.

As an organization is run by and for people with disabilities, DREDF calls for the adoption of the PACIO recommendations as a step that will help further advance the federal demographic data collection standards implemented by the federal Department of Health and Human Services almost 14 years ago.

Support for Moving Disability Status to Patient Demographics

As a disability/health scholar and social work professional who co-chairs the WHO Functioning and Disability Reference Group, I strongly support the recommendation to move disability status from Health Status Assessments to Patient Demographics. 

The change would signify an important shift in health care where disability moves away from being viewed as an individual medical problem to a recognized aspect of identity shaped by societal factors. The shift better aligns with global standards and terminology reflected in the International Classification of Functioning, Disability and Health, or ICF, where disability refers to the interaction between a person's health condition(s) and their contextual factors (environmental and personal factors). 

Collecting disability data in health records is a crucial first step toward identifying disparities in care and health outcomes that individuals with disabilities experience. It enables tracking differences in health statistics, such as disease prevalence and access to preventive services, between persons with and without disabilities. 

Documenting disability status as a patient demographic will allow healthcare providers to better identify and provide necessary accommodations and auxiliary aids, such as sign language interpreters or adjustable exam tables, to ensure equitable and effective care. 

This recommendation promotes a more inclusive approach to healthcare by allowing patients to report their own disability status, moving beyond a sole reliance on diagnostic codes often considered problematic.

Reclassifying Disability Status

Comments submitted by Barbara Kelley, Executive Director, Hearing Loss Association of America.

Disability is a demographic characteristic, not a clinical condition. Its current placement under Health Status Assessments risks conflating disability with illness or impairment, which can lead to misinterpretation and unintended consequences in care delivery and data analysis. Reclassifying Disability Status under Patient Demographics/Information would:

• Align with federal guidance from the HHS Data Council and CMS practices.
• Promote more accurate and respectful representation of individuals with disabilities.
• Enhance the utility of demographic data for equity analysis, population health, and policy development.

This change is essential to ensure that disability data is treated with the same rigor and respect as other demographic elements such as race, ethnicity, and gender identity.

Recommend Moving Disability Status to Patient Demographics

• Recommendation: Recommend moving the Disability Status data element to the Patient Demographics/Information data class.
• Rationale: The PACIO Project Community* recognizes and appreciates the significant work undertaken by the HHS Data Council in developing the Disability Status data collection standards. We understand the historical context and the deliberate efforts made by the Council and its dedicated workgroup to ensure that this data accurately captures necessary information, particularly as it relates to demographic data collection. The Council’s approach, as outlined in the "U.S. Department of Health And Human Services Implementation Guidance on Data Collection Standards for Race, Ethnicity, Sex, Primary Language, and Disability Status" clearly demonstrates that Disability Status is intended to be collected as part of demographic information, alongside race, ethnicity, and sex.
  • The PACIO Community’s ongoing concern is that Disability Status under USCDI continues to be classified under the Health Status Assessments data class, which does not reflect its primary purpose as a demographic identifier. Disability Status, like race, ethnicity, and sex, is a fundamental demographic characteristic and should be grouped accordingly to ensure consistency and clarity in data collection and use. Moving this data element to the Patient Demographics/Information data class would better align with the intent of the HHS Data Council and the standards described in the aforementioned guidance document.
  • Furthermore, collecting the patient asserted Disability Status as part of Health Status Assessments risks conflating disability with clinical health assessments, which may lead to misinterpretation or unintended consequences, such as influencing disability benefits or incorrectly classifying patients. Disability, as a demographic characteristic, does not inherently reflect a person’s health status, functional status, or cognitive status, which is typically captured under Health Status Assessments.
  • This recommendation is consistent with current practices in post-acute care (PAC) settings and aligns with CMS guidance, Inventory of Resources for Standardized Demographic and Language Data Collection. By classifying Disability Status within Patient Demographics/Information, we can more accurately capture and utilize this data for demographic analysis, support better clinical decision-making, and avoid conflating disability assertions with health assessments.
• Reference: The HHS Data Council serves as the principal, senior internal Departmental forum for coordinating HHS data collection and analysis activities. The Council’s workgroup leveraged extensive experience in collecting and analyzing demographic data to develop the Disability Status collection standard. U.S. Department of Health And Human Services Implementation Guidance on Data Collection Standards for Race, Ethnicity, Sex, Primary Language, and Disability Status
• * The PACIO (Post-Acute Care Interoperability) Project, established February 2019, is a collaborative effort between industry, government, and other stakeholders, that aims to advance interoperable health information exchange between post-acute care (PAC) providers, patients, and other key stakeholders across health care.