Tests that result in visual images requiring interpretation by a credentialed professional.

Data Element

Diagnostic Imaging Reference
Description (*Please confirm or update this field for the new USCDI version*)

Information that can be used to access a diagnostic imaging study.

Examples include but are not limited to imaging study endpoint weblink, unique identifiers, and contextual information needed to retrieve a diagnostic imaging study.

Comment

Emory Healthcare Comments on Diagnostic Imaging Reference

EHC strongly supports the inclusion of Diagnostic Imaging Reference and data elements that support the exchange of diagnostic imaging tests and results. Weblinks for images are an important part of efficient patient-facing image sharing which allows patients to access their own radiology images, on-demand. 

Medicom Comments on Draft USCDI v7

The Diagnostic Imaging Reference element is the single most consequential addition in Draft USCDI v7 from the perspective of enterprise imaging interoperability. It is the first USCDI data element to explicitly establish that diagnostic imaging studies must be electronically accessible and referenceable across health IT systems, a foundational step toward eliminating the physical media and proprietary silo dependencies that continue to fragment clinical imaging workflows across the United States.

The current definition "the information that can be used to access a diagnostic imaging study" correctly captures the intent of the element. However, it is insufficiently specific to ensure consistent, interoperable implementation. The accompanying examples ("imaging study endpoint weblink, unique identifiers, and contextual information needed to retrieve a diagnostic imaging study") describe the types of components but do not define the required structure, format, or technical mechanism. Without greater specificity, implementation will vary widely across EHR vendors, PACS vendors, and imaging exchange platforms, resulting in a fragmented ecosystem in which a reference generated by one system cannot be reliably consumed by another.

Medicom strongly recommends that ASTP/ONC update the Diagnostic Imaging Reference definition and usage notes to specify the following:

  • FHIR ImagingStudy Resource as the Preferred Representation: The HL7 FHIR ImagingStudy resource (R4/R5) is the most complete structured representation of a Diagnostic Imaging Reference. It natively captures the DICOM Study Instance UID, series-level metadata, the DICOMweb WADO-RS endpoint for image retrieval, and contextual links to the ordering provider (ServiceRequest) and the resulting report (DiagnosticReport). ASTP/ONC should specify the FHIR ImagingStudy resource as the required representation for certified health IT systems implementing this element.
  • DICOM Study Instance UID as Required Identifier: The DICOM Study Instance UID is the globally unique, persistent identifier for every diagnostic imaging study and is universally captured by all PACS and VNA systems worldwide. Any compliant Diagnostic Imaging Reference must include this identifier. The accession number, while operationally important within a given facility's radiology information system (RIS) and PACS workflow, is facility-specific and not globally unique; it should be characterized as a complementary identifier within the reference.
  • DICOMweb WADO-RS Endpoint as the Required Retrieval Mechanism: The Diagnostic Imaging Reference must specify a machine-readable, standards-based retrieval mechanism. Medicom recommends requiring a DICOMweb WADO-RS (Web Access to DICOM Objects by RESTful Services) endpoint as the primary retrieval mechanism. DICOMweb is a DICOM standard (PS3.18) that enables web-based retrieval of imaging studies using standard HTTP APIs, making it compatible with modern EHR and application integration frameworks. It is implemented in production today by leading PACS vendors and imaging platforms and is the cornerstone of SMART Imaging Access and IHE SMART-on-FHIR workflows for imaging.
  • Sufficient Patient and Study Context: Beyond the technical identifiers, a compliant Diagnostic Imaging Reference should include sufficient contextual information to enable unambiguous study identification across organizational boundaries, such as patient identifier (MRN or national patient identifier); Study date; Imaging modality; and Imaging body region, where available. This context is critical for patient matching and for clinical disambiguation when multiple studies share similar characteristics.

Another important step is enhancing the FHIR ImagingStudy resource to include the transfer syntax necessary to enable DICOMweb. Together, these open the door for patients to directly access medical images from a preferred application or service while reducing the infrastructure and integration burden. This unlocking of patients’ medical images allows them to market-select any third-party viewing or analysis app.

Addressing the remaining barriers to patient imaging access will require continued progress toward standards-based interoperability between imaging systems, EHRs, and patient-facing applications. Ensuring that diagnostic imaging can be surfaced and exchanged through the same mechanisms used for other clinical data will be necessary for patients to fully access and manage their complete health record.

Medicom's operational experience across more than 2,500 institutions confirms that when these three technical components are present and standardized, seamless cross-institutional imaging retrieval is achievable today. When any one of them is absent or non-standardized, manual processes, proprietary integrations, and physical media reliance persist. The Diagnostic Imaging Reference element has an opportunity to be the regulatory lever that drives consistent adoption, but only if the definition provides the technical specificity needed for interoperable implementation.

Generalize the Diagnostic Imaging Reference for greater utility

Diagnostic Imaging Reference

The information that can be used to access a diagnostic imaging study.

Examples include but are not limited to imaging study endpoint weblink, unique identifiers, and contextual information needed to retrieve a diagnostic imaging study.

Comment: Many different kinds of documents such as reports, plans, notes, letters, explanations etc. can be retrieved by virtue of an endpoint weblink, unique identifiers, and contextual information. The data element should be introduced generally so as to minimize the bloat of USCDI data elements.

Recommendation: Consider Creating a general data element in the context of the Healthcare Information Attributes data class called Document Reference define it as being the information that can be used to access a document or referenceable collection of information which can be retrieved as a meaningful assemblage of information about the patient or a patient’s encounter or delivered healthcare service(s). 

Examples include but are not limited to an endpoint weblink, unique identifiers, and contextual information needed to retrieve a document containing the information described in the Document Reference.

This data element is essential to elevate discoverability of imaging data.

CMS and the ONC should consider alignment with NEN 7541 for imaging retrieval across payers, providers, delegate entities, and PACS systems.

https://connect.nen.nl/Standard/Detail/3802320?compId=0&collectionId=0

ACR USCDI Draft V7 Comments - Diagnostic Imaging

The American College of Radiology (ACR) fully supports the inclusion of Diagnostic Imaging Reference as a required data element in USCDI Version 7. Although robust technical standards and implementation mechanisms for imaging exchange have long been in place, the absence of regulatory requirements has limited consistent adoption across the healthcare ecosystem. As a result, patients frequently experience avoidable delays in care, including challenges in comparing prior examinations, unnecessary repeat imaging, and the inability of receiving clinicians to review imaging prior to patient transfer.

The forthcoming normative status of the ImagingStudy resource in FHIR Release 6, combined with the demonstrated success of the Argonaut SMART Imaging project, clearly shows that the technical ability to support seamless imaging exchange already exists. These efforts proved that current standards and technology fully support secure access, authorization, and consistent implementation of imaging exchange workflows. Incorporating Diagnostic Imaging Reference into USCDI v7 elevates imaging-related FHIR resources to first‑class status, enabling them to more effectively support patient care and improve clinician efficiency, patient satisfaction, and clinical outcomes.

Recognizing diagnostic images as an integral component of the medical record—equivalent to clinical history, laboratory values, and medication lists—is essential to ensuring a complete and accurate picture of a patient’s health. Incorporating this data element into USCDI v7 ensures that, when appropriate permissions for information exchange exist, imaging will be reliably available to all clinicians involved in the continuum of care.

A mandated and standardized approach to imaging exchange will meaningfully reduce unnecessary radiation exposure, prevent redundant examinations due to unavailable prior imaging, lower healthcare costs for patients and payers, and improve clinical outcomes by enabling timely access to critical diagnostic information. The ACR strongly recommends the final adoption of this data element to advance interoperability, patient safety, and high-quality care.

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