Submitted by CDC_DSMH_WG on
CDC-CMS Joint Priority Data Element for USCDI v4
We support the CMS comment ‘CMS-CCSQ Support for Facility/Organization Identifier: USCDIv3’ on 2022-03-22 that Facility/Organization Identifiers are critical component of EHR for providing high quality care to patients, reducing disparities, SDOH data analysis, promoting interoperability and data aggregation. HIPAA requires that health care providers have standard NPI that identify them on all standard transactions. We recommend adding the ‘Facility/Organization Identifiers’ to USCDI data classes. We suggest the following definition of this data class: ‘Facility/Organization Identifiers in EHRs are standardized codes, names and other attributes that provide a unique data pointer to a healthcare facility/organization where patient’s care has occurred.’
We found a similar concept description in the Level 2 under the ‘Facility Level Data’. Because a potential ambiguity of the ‘Facility Level Data’ term (i.e., it could mean aggregate level facility data rather than unique identifiers) we strongly suggest replacing it with proposed by CMS title ‘Facility/Organization Identifiers’. Based on the recent experience in management of the COVID-19 EHRs and ONC requirements on EHR aggregation and reporting data for situational awareness, we propose that the following data elements and associated vocabulary standards should be included into the Facility/Organization Identifiers data class:
- Organization/Facility name, LOINC 76469-6
- Organization/Facility Email address, LOINC 90054-8
- Organization/Facility Phone number, LOINC 90053-0
- Organization/Facility Address, LOINC 90052-2
- Organization/Facility ZIP code , LOINC 76695-6
- National Provider ID (NPI), LOINC 45952-9
- CCN (CMS Certification Number), LOINC 69417-4
Additional applicable standards and additional specifications:
- FHIR DSTU2, 3 and 4, CDA Release 2.0, HL7 V2 PL Data Type https://bit.ly/FHIRLocation,
- Resource Profile: FHIR 5.0.1 - STU5 Release US, US Core Location Profile https://open.epic.com/Interface/FHIR#Location
- FHIR 4.3.0: R4B – STU, Resource Organization - Detailed Descriptions https://hl7.org/fhir/organization-definitions.html
- HHS.gov. Health Information Privacy. Other Administrative Simplification Rules. https://www.hhs.gov/hipaa/for-professionals/other-administration-simplification-rules/index.html
This element is also shared priority for both CDC and CMS as outlined in the joint support letter







Submitted by CDC_DSMH_WG on
CDC's comment on behalf of CSTE for USCDI v4
CSTE agrees with CDC's recommendation for this data element.