The metadata, or extra information about data, regarding who created the data and when it was created.

Data Element
Patient Digital Identity Credential
Submitted By: Trinh, C. / MyRxWallet DAO, LLC, A MyRxWallet North America Corporation subsidiary
Data Element Information
Data Element Description A portable, patient-controlled identity credential providing a cryptographic or standards-based binding between the credential and the individual (not a device or account), with explicit consent authorization records tied to that identity. Must be FHIR R4/R5 native (Patient resource + Consent resource) and must not require PHI to be stored in a third-party system to function.
Rationale for Separate Consideration Existing Patient Demographics/Information addresses administrative matching only. This element addresses cryptographic identity binding — verifiable at the individual level, not the record level. Demographic matching cannot prevent duplicate records, misidentification, or information blocking. This element solves the problem structurally.
Use Case Description(s)
Use Case Description Patient identity verification at point of care: a clinician initiates a patient encounter and must confirm the patient's identity before accessing or exchanging records. A verified digital identity credential is presented by the patient (via wallet app or QR code), cryptographically confirmed, and anchored to the FHIR Encounter resource — creating an auditable record of who was identified, when, and under what authorization. Use cases include: emergency department admission, prescription dispensing, specialist referral, telehealth authentication, and cross-organizational record exchange via TEFCA QHINs.
Estimate the breadth of applicability of the use case(s) for this data element Patient digital identity applies to every care setting — hospitals, clinics, pharmacies, telehealth, emergency — no specialty restriction.
Link to use case project page https://trinh.io
Supporting Attachments v3- Public Comment • USCDI Version 7 • ONC - Healthit.gov • April 11, 2026.pdf
Use Case Description Drug supply chain integrity: patient identity anchored to DSCSA-compliant medication dispense records via MedicationDispense FHIR resource, enabling a verifiable chain of custody from manufacturer to patient. Public health emergency response: verified patient identity enables rapid, accurate record retrieval across organizations during disasters or disease outbreaks without reliance on fragile demographic matching.
Estimate the breadth of applicability of the use case(s) for this data element All U.S. healthcare providers, payers, pharmacies, and patients — approximately 6,000+ hospitals, 300,000+ physician practices, 60,000+ pharmacies, and 330 million patients nationwide.
Link to use case project page https://trinh.io
ONC Priority
  • Mitigate health and health care inequities and disparities
  • Address the needs of underserved communities
Maturity of Use and Technical Specifications for Data Element
Applicable Standard(s) W3C Decentralized Identifiers (DID) Core 1.0; W3C Verifiable Credentials Data Model 1.1; HL7 FHIR R4 Patient resource; HL7 FHIR R4 Consent resource
https://www.w3.org/TR/did-core/
Additional Specifications HL7 FHIR R4 US Core Patient Profile; SMART on FHIR; W3C DID Core Implementation Guide. Reference implementation available at trinh.io.
Current Use (Level 0) Captured, stored, or accessed in limited settings such as a pilot or proof of concept demonstration
Extent of exchange N/A
Potential Challenges
Restrictions on Standardization (e.g. proprietary code) No proprietary code. All referenced standards are open: W3C DID Core 1.0 and Verifiable Credentials are royalty-free open standards; HL7 FHIR R4 is openly published. Primary standardization challenge is the absence of ONC guidance on integrating W3C DID/VC specifications with FHIR US Core profiles — a gap this submission is intended to help address.
Restrictions on Use (e.g. licensing, user fees) None. W3C and HL7 FHIR standards referenced here are open and freely accessible. No licensing fees or user fees apply to the underlying standards.
Privacy and Security Concerns The proposed architecture is zero-knowledge at the provenance layer — no PHI is stored on-chain or in the identity credential itself. The credential binds identity cryptographically without containing protected health information. This design is fully HIPAA-compatible. Patient controls their own credential; no custodial third party holds PHI. Server breach does not constitute a HIPAA breach under this architecture.
Estimate of Overall Burden Moderate initial integration effort for EHR vendors. FHIR R4 APIs are already required under HTI-5, reducing marginal burden significantly. Patient onboarding is a single enrollment event. W3C DID wallet infrastructure is open-source and available. Estimated developer implementation time: comparable to existing SMART on FHIR integration work.
Other Implementation Challenges Cultural and workflow adoption: clinicians and front-desk staff require training on credential verification workflows. Patient digital literacy varies — onboarding support needed for underserved populations. No current federal mandate exists for DID-based identity, though EO 14178 (January 23, 2025) establishes self-custody wallets as national policy, creating a favorable regulatory environment.
ONC Evaluation Details
Each submitted Data Element has been evaluated based on the following criteria. The overall Level classification is a composite of the maturity based on these individual criteria. This information can be used to identify areas that require additional work to raise the overall classification level and consideration for inclusion in future versions of USCDI
Criterion #1
Maturity - Current Standards		 Level 0 - Data element is not represented by a terminology standard or SDO-balloted technical specification or implementation guide.
Criterion #2
Maturity - Current Use 		Level 0 - Data element is captured, stored, or accessed in limited settings such as a pilot or proof of concept demonstration.
Criterion #3
Maturity - Current Exchange		 Level 0 - Data element is electronically exchanged in limited environments, such as connectathons or pilots.
Criterion #4
Use Case(s) - Breadth of Applicability		 Level 0 - Use cases apply to a limited number of care settings or specialties, or data element represents a specialization of other, more general data elements.

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