USCDI v7 and the End of Incrementalism
The history of ASTP's slowest moving program (as told by tweets) and the new phase of regulatory acceleration
Sometimes the government just goes and has a DAY. For the ASTP, yesterday was one of those days. It’s almost like they went through and checked off my wish list, as they announced a proposed USCDI version 7 that, contrary to prior incremental iterations, was loaded to the brim with hugely impactful new data classes. They also released a new Request for Information focused on Diagnostic Imaging, a long-time passion of mine that has been chronically underaddressed as an interoperability focus.
USCDI
For those out of the loop, USCDI is the United States Core Data for Interoperability: the federally defined baseline set of health data classes and elements that certified health IT must be able to exchange. It is the substrate underneath certification, information-blocking enforcement, and, increasingly, payer and public-health policy.
It’s worth noting that, like so many of the other backflips we do in our convoluted health technology regulatory apparatus, USCDI doesn’t compel action on its own. It has to be referenced in other enforcement regimes, like HTI rules, before most actors have a reason to invest. The annual versioning process is largely procedural, but it does serve an important function: each new release triggers the US Core update cycle, which is where vague data classes get translated into concrete FHIR profiles that vendors and implementers actually have to grapple with.
Time Machine
USCDI releases to date have been incremental and conservative. New versions typically refine definitions, add a handful of data elements, or slightly expand scope. Jumping in the hot tub, we can warp back and review thoughts I had around prior versions.
I wasn’t a big fan of the initial USCDI drop, mainly because it was so similar to previous standards:
No real change for USCDI v2, which added three new data classes (Clinical Tests, Diagnostic Imaging, and Encounter Information) that were largely in CDAs already:
USCDI v3 really just added health insurance:
USCDI v4 had very little to comment on, as well. When your big update is the “Facility Information” data class, well, you get this:
Dialogue around USCDI v5 started to highlight my frustration a bit more:
Draft USCDI v5 is out.
The main addition is the new data class of Orders. Useful to see the full picture of what physicians want for a patient (which pairs with what’s been completed via Labs and Procedures)
But if you think planned orders are good, planned encounters should be included as well.
Administrative aspects of the patient’s care, like appointments and financial data, continue to be left out, but have some of the biggest unlocks.
And when it comes to USCDI v6, which mainly added Family Health History as a data class? I can’t even find tweets or posts I had about it, which, coming from someone who reliably has opinions and takes on interoperability to a fault, is a fairly damning data point.
This administration is, as the kids say, “built different”, however! There’s something for everyone here:
