Reporting Year 2024 UDS+ Requirements

[anthonygalba]

At the last UTC call, HRSA clarified there would be some "minimum required scope" for UDS+ in reporting year 2024. That scope is not defined in any public UDS+ documentation, the IG, or the HRSA UDS+ website. The 2024 reporting year is already ongoing without health centers or EHR vendors understanding what the requirements will entail. Please provide guidance on what exactly will be required for UDS+ in 2024 as soon as possible, so health centers can plan their build, upgrades, and support around those requirements.

[cooperthompson]

I will add, that for many other reporting programs, we (Epic, but also EHRA) usually request ~18 months to perform spec analysis, develop support for the spec, then roll out that support to our customers. Anything less than 18 months usually ends up being more expensive, as we need to retrofit the support to older versions of our software, and our customers need to coordinate taking those updates, and perform testing of the code we deliver.

[joshua-hiltunen]

I asked about this elsewhere, and I'll add my question and the response I got back, which I thought was helpful in terms of how I'm looking at scope.

I think the question “What resources do we need to support for UDS+ reporting?” keeps coming up, and the answer has not been very firm. My initial thinking was this was because the specification was very much in flux as initial implementers ran across issues and raised concerns.

Over the past week, I started thinking that it was a little more nuanced than that. Is the refusal to provide a firm “You must support X,Y, and Z” because the nature of EHRs is such that information can be represented differently across systems? You care more about getting the supporting information you need than that every resource you’ve identified as possibly containing that information is there?

In other words, the Resource requirement is specific to the EHR, because the EHR is producing the information. You don’t expect that they will be recorded or show up the same way in every system, and so when you say “that depends” when people ask which Resources they need to support, you mean it. It depends on the software that a participating clinic is using, and even on how they’re capturing information within the EHR.

Response (courtesy Rachel Fried):

You have the right idea about the “it depends”! We have tried to be clearer about this in the last few UDS+ Office Hours and the FAQs, as we find code sets and values during testing that are different across IT set-ups. Did you happen to catch our review of the eCQMs where we talked about the need to provide the elements related to the Resource requirements under the minimum necessary?

Based on the response, the list of resources and mappings indicates the set of places that HRSA/UDS+ believes the data they need to support UDS+ reporting lives. Their hesitation to say "you must implement all of X,Y, and Z" is a nod to the fact that workflows and the resultant data looks very different from EHR to EHR. We, as EHR vendors, need to look at how we translate the data in our systems to FHIR resources, and our minimum scope is "the subset of Resources that covers the data elements that the tables are based on."

HRSA cannot tell you what that set of FHIR Resources is because if they're too firm, they exclude the possibility of participation altogether for users of EHR software that doesn't capture enough information to support a required Resource, and if they're too lenient they don't get the information they need.