Submitted by mbenitz on
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.







Submitted by EmoryHealthcare on
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.