Submitted by RebeccaB on
ASHA: Add ICF as an as an Applicable Vocabulary Standard
On behalf of the American Speech-Language-Hearing Association (ASHA), I write to share ASHA’s support of PACIO's recommendation to add the International Classification of Functioning, Disability and Health (ICF) as an Applicable Vocabulary Standard to the Functional Status, Health Concerns, and Mental/Cognitive Status data elements. . 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.
Recommendation: Add the International Classification of Functioning, Disability and Health (ICF) as an Applicable Vocabulary Standard to the Functional Status, Health Concerns, and Mental/Cognitive Status data elements.
Rationale: The PACIO Project Community* recommends the addition of the World Health Organization’s International Classification of Functioning, Disability and Health (ICF) as an Applicable Vocabulary Standard to the Health Concern data element.
- 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.
- The WHO developed the ICF to be ICD complementary, with ICF covering functioning and environmental factors and ICD covering diseases and other health problems. As described by the WHO, “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 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.
Current Standards
Current Use
- All post-acute care (PAC) vendors can collect data pertaining to Functional Status and Mental/Cognitive Status given CMS requirements to collect such data required for PAC facilities to get reimbursement (e.g., Minimum Data Set for nursing facilities, Inpatient Rehabilitation Facility Patient Assessment Instrument [IRF-PAI]); therefore, all vendors have the potential to apply ICF to the volume of Functional Status and Mental/Cognitive Status data already collected.
- Three vendors have deployed the PACIO PFE IG that integrates the ICF: Global Alliant, Open City Labs, and Patient Centric Solutions.
Current Exchange
- The ICF-integrated PACIO PFE IG has been used to successfully exchange ICF-coded data during the July 2025 CMS Connectathon applied to the PHQ-9 assessment and January 2026 HL7 Conenctathon applied to the PROMIS-10 measure.







Submitted by ubackonja@mitre.org on
PACIO: Add ICF to Health Concern
Recommendation: Add the International Classification of Functioning, Disability and Health (ICF) as an Applicable Vocabulary Standard for Health Concern, 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 Health Concern 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 Health Concerns 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.
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:
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:
Current Exchange:
Active Exchange: The ICD-API includes the ICF as a CodeSystem in FHIR.
Recent demonstration:
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.