NCQA Comments on USCDI version 7

NCQA recommends updates and additions to USCDI v7 to enhance data standards, including tobacco use, imaging terminology, discharge summaries, and race/ethnicity alignment with OMB guidance.

September 29, 2025

Thomas Keane
Assistant Secretary for Technology Policy
U.S. Department of Health and Human Services
330 C Street SW, 7th Floor
Washington, DC 20201

Dear Dr. Keane:

The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide submissions for the US Core Data for Interoperability (USCDI) version 7. 

NCQA is a private, 501(c)(3) not-for-profit, independent organization dedicated to improving health care quality through our Accreditation and measurement programs. We are a national leader in quality oversight and a pioneer in quality measurement. Leveraging our strengths as a trusted third party, we are committed to helping organizations navigate the challenges associated with improving the health care system. Our mission to improve the quality of health for all Americans propels our daily work. 

NCQA is pleased to provide the following recommendations, summarized below and detailed on the following page for USCDI v7.

We recommend modifications to the following USCDI elements:

  1. Health Status Assessments, Smoking Status: Expand the element definition to include tobacco use and expand the terminology to include LOINC.
  2. Diagnostic Imaging, Diagnostic Imaging Report: Expand the terminology requirements for structured capture of interpretation of results (SNOMED, RadLex).
  3. Clinical Notes, Discharge Summary Note: Revise the required elements of discharge summaries to align to practice.
  4. Patient Information, Race and Ethnicity: Update the Race and Ethnicity data elements to align with the OMB revisions to the SPD 15, published on March 2024. 

We recommend adding the following elements to USCDI v7:

  1. Orders, Referral Orders
  2. Orders, Medical Device Orders
  3. Health Status Assessments, Goal Assessment (new submission)
  4. Explanation of Benefits, Carin Blue Button CPCDS elements

Thank you for the opportunity to comment. We remain committed to working with ASTP to build a more efficient and responsible American health care system. If you have any questions, please contact me at (202) 955-3590, or at musser@ncqa.org.

Sincerely,

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Eric Musser
Vice President, Federal Affairs

Detailed Recommendations

  1. Modifications to existing USCDI elements
    Health Status Assessments: Smoking Status

    1. Recommendation: Expand the scope of the Smoking Status element to include assessment of all tobacco products, aligned to the FDA definition for tobacco use; modify the element name and description to define the expanded element as assessments of a patient’s tobacco use behaviors including use of smoke, vape, chew, or sniff tobacco products. We also recommend adding duration (number of years of use) and quit date in the list of example data elements for comprehensive tobacco use history. Add LOINC terminology to the vocabulary standards.
    2. Rationale: Tobacco assessment and use status encompasses assessment of broader tobacco product use beyond smoked products/cigarettes defined in the existing ‘Smoking Status’ USCDI element. Comprehensive assessment of tobacco use remains a public health priority and is essential to appropriately providing cessation intervention. Intervention should be provided for any tobacco use, not just smoked products/cigarettes. NCQA recently introduced a new HEDIS® measure to incentivize routine tobacco use screening and cessation intervention; this data is routinely captured with standard terminology.

    Diagnostic Imaging: Diagnostic Imaging Report

    1. Recommendation: The current USCDI element includes both the structured and unstructured components of the report. We recommend adding RadLex and SNOMED CT as appropriate vocabulary standards representing the clinical findings from the structured components of an imaging report.
    2. Rationale: The clinical conclusions or findings resulting from a diagnostic imaging study represent important information to be exchanged via standard terminology to support appropriate follow-up care and care coordination. NCQA continues to develop measures that require the findings from imaging reports, which routinely represent the clinical findings using the ACR Reporting and Data Systems (RADS) or SNOMED CT. Via quality measure testing with health systems and health plans, NCQA identified that while clinical findings are represented standardly, they are not always mapped to the available terminology codes. Adding SNOMED CT and RadLex vocabulary standards to the USCDI element will enhance standardization, reduce burden, and enhance interoperable exchange of these important data.

    Clinical Notes: Discharge Summary Note

    1. Recommendation: Update the required components of a discharge summary note to include: reason for encounter, discharge diagnoses, procedures or treatment provided, current medications, patient instructions, and pending tests.
    2. Rationale: High-quality discharge summaries are considered essential for promoting patient safety during transitions between care settings. The recommended required components of the discharge summary align to requirements set by NCQA’s HEDIS measure (Transitions of Care) used in CMS Medicare Advantage Stars and aligns to The Joint Commission requirements. Aligning USCDI requirements to industry standards supports reinforcement of high quality discharge summaries to support transitions of care.

    Patient Demographic/Information: Race and Ethnicity

    1. Recommendation: Update the Race and Ethnicity data elements to align with the OMB revisions to the Statistical Policy Directive No. 15: Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity (SPD 15), published on March 29, 2024. First, in alignment with the revised SPD 15, we recommend ASTP combine the individual race and ethnicity elements to create one data element: Race and/or Ethnicity. Second, we recommend ASTP update the vocabulary standards for the Race and/or Ethnicity data element to reference the March 2024 revised SPD 15.
    2. Rationale: NCQA supports ASTP’s stated plans to modify the existing Race and Ethnicity elements and terminology requirements to support implementation of the updated OMB SPD 15 standard in future USCDI versions. We recommend USCDI update to align as early as possible (well in advance of the March 2029 OMB deadline) to support clear requirements and alignment of standards across the industry.
  2. New elements for USCDI v7
    Orders: Referral Orders

    1. Recommendation: Add an additional element to the Orders data class for Referral Orders, defined as a provider-authored request to another provider, specialist, or organization for care services. Examples include referral orders to a wound specialist or podiatrist. (Vocabulary standards: SNOMED CT)
    2. Rationale: Referral Orders are another important order data element to support care coordination and are already routinely exchanged. Inclusion in USCDI should also facilitate the ability to close the loop on referrals to ensure services requested are carried out, and care is provided, which is the critical step for high-quality, equitable care. NCQA continues to add follow-up components to many new and existing measures to assess for appropriate care following a significant medical finding; referral orders are one component to appropriate follow-up.

    Orders: Medical Device Orders

    1. Recommendation: Add an additional element to the Orders data class for Medical Device Orders, defined as a provider-authored request for medical devices, such as for therapeutic footwear or walking aids (Vocabulary standards: SNOMED CT).
    2. Rationale: Medical device orders represent another important type of order for appropriate care and patient support. These orders can be captured and exchanged via standard vocabulary. NCQA is currently developing a measure for foot exam and appropriate follow-up in persons with diabetes, as diabetes remains a prevalent and costly disease among adults in the United States.

    Health Status Assessments, Goal Assessment (new submission)

    1. Recommendation: Add a new element goal assessment, defined as the assessment and monitoring of goals and goal progress. Examples for goal assessments include Goal Attainment Scaling (GAS) and patient-reported outcome measures (PROMs) such as PHQ-9, GAD-7 or PROMIS.
    2. Rationale: Inclusion of person-centered information in care continues to be a priority across the ecosystem. Sharing of critical patient-centered data across care settings supports prioritization of a person’s well-being rather than just treating symptoms. While patient goals are included in USCDI, standardized assessment tools to monitor and track goal progress are a critical missing component to USCDI.  Standardized tools exist, such as goal attainment scaling (GAS) and PROMIS tools, to track and assess goals overtime. This allows patients, caregivers and clinicians to meaningfully and standardly track progress on goals and have meaningful conversations related to individual goals. While USCDI includes some elements that may encompass tools used for goal assessment, an explicit USCDI element to clarify expectations and notate additional tools (like GAS) is important to ensure person-centered information is available and used in care.

    Explanation of Benefits: Carin Blue Button (BB) Common Payer Consumer Data Set (CPCDS) elements

    1. Recommendation: Add Carin BB CPCDS elements related to explanation of benefits to USCDI v7 (currently Level 0 elements- Explanation of Benefits data class) to support exchange of adjudicated claims information without financial information, as proposed by Carin Alliance. The following are NCQA priorities based on use in HEDIS:
      • Claim Service Start Date
      • Claim Service End Date
      • Service (from) Date
      • Service to Date
      • Payer Claim Unique Identifier
      • Claim Type
      • Claim Sub Type
      • Statement From Date
      • Statement Thru Date
      • Claim Type of Bill Code
      • Place of Service Code
      • Revenue Center Code
      • National Drug Code
      • Quantity Dispensed
      • Days Supply
      • Diagnosis Code
      • Diagnosis Code Type
      • Procedure Code
      • Procedure Date
      • Modifier Code
      • Line Number
    2. Rationale: NCQA continues to recommend that the Carin BB CPCDS elements be added to USCDI to support exchange of adjudicated claims information (without financial information), as proposed by Carin Alliance. The CMS Interoperability and Prior Authorization Final Rule requires payers to share patient claims and encounter data with in-network providers with whom the patient has a treatment relationship. This requirement provides a direct scenario where EHRs may begin to accept, store and use Carin BB CPCDS elements. Adding CPCDS elements under the Explanation of Benefits data class (Level 0 in ONDEC) to USCDI aligns requirements across payers and health IT and will improve data sharing abilities across health plans and providers. Information sharing reduces redundancy in data collection, can improve the patient experience, and can support record location.
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