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April 17, 2023

AMIA appreciates ONC’s efforts to solicit feedback on data collection for future iterations of USCDI. Overall, AMIA encourages ONC to ensure that USCDI will decrease burden with common elements for interoperable exchange. Increasing burden on clinical workflow will be a detriment to all stakeholders. We believe the lack of clear definition of certain data classes and elements will add to burden. Notably, we recognize the overarching challenge to craft this common data set to be equally credible, electronically consumable, and useful to patients, providers and payers alike.