NCQA Submits Comments on USCDI Draft Version 6
April 30, 2025 · Becky Kolinski
The United States Core Data for Interoperability (USCDI) sets standards for nationwide electronic data exchange that support the transition to digital quality measurement. NCQA recently submitted comments to the Assistant Secretary for Technology Policy (ASTP) about USCDI Draft Version 6.
We encourage health care organizations to review NCQA’s recommendations and submit comments to ASTP by May 12.
What Is USCDI?
USCDI is a set of health data classes and data elements that support interoperable health information exchange. Updated annually, each USCDI version builds on the previous one by adding new data elements and classes and refining existing standards based on stakeholder feedback.
USCDI is the standard for certain criteria within the Health IT Certification Program, and exchange networks such as TEFCA require the capability to exchange USCDI data elements. ASTP will require USCDI version 3 in 2026, but health care organizations can choose to adopt a higher version of USCDI prior to the regulatory “floor” being updated.
What Are the Proposed Changes to USCDI?
Updates to this version of the USCDI are driven by two key policy priorities:
- Minimizing the implementation burden.
- Adding data elements to support improved health outcomes, public health reporting and behavioral health integration with primary care.
The new version of USCDI adds six new data elements and removes three elements. View all the changes to USCDI draft version 6 here.
What Does NCQA Recommend?
NCQA provided comments on two data elements in response to questions posed by ASTP, recommended additional data elements and offered comments on existing elements and other related topics.
Comments on Data Elements With Posed Questions
- NCQA supports adding Care Plan to the Patient Summary and Plan data class. Care plans are critical components for high quality, person-centered care and care coordination. NCQA uses care plans in our person-centered outcomes measures, and we are working with HL7 to develop a Person-Centered Outcomes FHIR® Implementation Guide.
- NCQA supports adding details to the Diagnostic Imaging data class to provide usable information related to diagnostic imaging tests and results. Imaging data used in quality measures—such as mammograms and CT scans for breast and lung cancer screening—require findings from imaging reports. Clarifying terminology requirements (RadLex, SNOMED, LOINC) for the structured components of diagnostic imaging reports in the USCDI elements will enhance standardization and reduce burden.
Recommendations for Existing Data Elements
- Update the Discharge Summary Note in the Clinical Notes data class to include the required components of a discharge summary. Aligning USCDI requirements to industry standards encourages organizations to create high-quality discharge summaries to support transitions of care. The required components of the discharge summary in NCQA’s Transitions of Care HEDIS® measure align with the CMS Medicare Advantage Stars program and Joint Commission requirements.
- Update Smoking Status in the Health Status Assessments data class to include assessment of all tobacco products, or add a new data element for Tobacco Use Status. Comprehensive assessment of tobacco use—smoke, vape, chew or sniff tobacco products—is essential for providing appropriate cessation intervention. NCQA is developing a measure to incentivize routine tobacco use screening and cessation intervention; these data are routinely captured with standard terminology.
Comments on Patient Demographics Data Class
- NCQA supports adding Veteran Status to the Patient Demographic/Information data class. This data element can support clinical and administrative workflows, help ensure continuity of care and improve health outcomes for veterans.
- NCQA supports modifying Race and Ethnicity elements in the Patient Demographic/Information data class to support implementation of the updated OMB SPD 15 standard. We recommend making this update to USCDI as early as possible, to allow organizations to prepare for the March 2029 OMB deadline.
Recommendation to Create a New Data Class
- NCQA recommends adding the Carin Blue Button Common Payer Consumer Data Set elements to USCDI. Adding these elements under a new Explanation of Benefits data class in USCDI will align requirements across payers and health IT, and improve data-sharing abilities across health plans and providers.
For more information, read NCQA’s full public comment letter.
What’s Next?
NCQA supports consensus-based processes, and encourages health care organizations to share feedback with ASTP to help advance data exchange and advance the evolution of digital quality measurement.
The public comment period for USCDI draft version 6 concludes on May 12. ASTP will review feedback and publish the final version in the coming months.
HEDIS® is a registered trademark of the National Committee for Quality Assurance (NCQA).
FHIR® is a registered trademark of Health Level Seven International and its use does not constitute endorsement by HL7.
