USCDI V1 to V3 Uplift: A Guide to CMS Compliance Requirements

The U.S. Core Data for Interoperability (USCDI) is a key standard set by the U.S. Department of Health and Human Services (HHS) aimed at improving health data exchange and patient care. As part of the effort to achieve nationwide health information interoperability, the USCDI has undergone several updates. With the release of USCDI V3, healthcare organizations must adapt to new requirements in order to remain compliant with regulations, especially those governed by the Centers for Medicare & Medicaid Services (CMS).

This post will outline the USCDI V1 to V3 uplift requirements and provide insights into how healthcare providers and organizations can meet the compliance expectations set forth by CMS.

What is USCDI?

The United States Core Data for Interoperability (USCDI) is a standardized set of health data classes and data elements that are deemed critical for interoperability across the U.S. healthcare system. It is foundational for improving the quality of care and ensuring that patient data is accessible and actionable across various platforms.

• USCDI V1: The initial version required as part of CMS-9115-F (among other regulations), which laid the groundwork for the core data elements required for interoperability.
• USCDI V2: Expanded the number of data elements and provided more comprehensive guidance including Social Determinants of Health (SDOH).
• USCDI V3: The latest CMS-sanctioned update, with new data classes and elements focused on increasing the standardization and accessibility of critical health information.

Key Changes from USCDI V1 to V3

The uplift from USCDI V1 to V3 includes several important changes that organizations need to be aware of:

1. New Data Classes and Elements: V3 introduces new data classes and elements that are essential for the interoperability framework. For example, new data types related to Social Determinants of Health (SDOH) and patient-reported outcomes (PRO) have been added to enhance the richness of health data.
2. Expanded Clinical Data: V3 places a stronger emphasis on clinical data, particularly around advanced directives, allergies, medication management, and problem lists. These areas are critical for improving care coordination and clinical decision-making.
3. Improved Structured Data Requirements: With V3, there’s a clearer push towards structured data for ease of exchange and better data usability. For example, the expansion of the data elements within the Care Team Members data class. This is particularly important for compliance with CMS regulations that require accurate and timely data reporting and exchange.
4. Inclusion of Patient-Generated Health Data: V3 focuses on incorporating data that is directly submitted by patients, including wearable device data and self-reported health information, aligning with the patient-centric approach in healthcare.

CMS Compliance and the USCDI Uplift

The Centers for Medicare & Medicaid Services (CMS) plays a key role in driving health information exchange, and its compliance requirements align closely with the implementation of USCDI standards. As CMS pushes for improved interoperability, healthcare organizations must ensure they are fully compliant with the latest versions of USCDI. USCDI V1 will expire January 1, 2026 and USCDI V3 becomes the new required version on that same date, with an implementation date of Jan 1, 2027. 

CMS Rules Affected by USCDI V3:

1. Promoting Interoperability (PI) Programs: Under CMS’s Promoting Interoperability programs, healthcare providers need to meet specific criteria related to data access, exchange, and submission. Compliance with USCDI V3 ensures that healthcare organizations align with CMS requirements for data sharing, particularly around patient access and electronic exchange.
2. Information Blocking Rule: The 21st Century Cures Act prohibits information blocking, and CMS enforces this by requiring that healthcare systems enable patients to access their data without undue delay. The inclusion of new data elements in USCDI V3 (such as social determinants of health) is aligned with this goal of empowering patients with comprehensive and actionable data.
3. Electronic Health Record (EHR) Certification: Healthcare providers must use certified EHR systems that meet specific criteria set by CMS. The USCDI V3 update will require vendors to update their systems to support the new data classes and elements mandated by the latest regulations.

Uplift Requirements: How Healthcare Organizations Can Prepare

1. EHR System Updates: Healthcare organizations should work closely with their EHR vendors to ensure that their systems are capable of handling and transmitting the newly required USCDI V3 data elements for use within the various APIs that are required for CMS-0057-F. Ensuring compliance may involve software upgrades and staff training.

1. Data Governance and Documentation: Effective data governance strategies are critical for maintaining the integrity and accuracy of health information. Healthcare providers need to ensure that data is structured, accurate, and accessible according to the new USCDI V3 standards.

1. Interoperability Testing: To ensure compliance with CMS requirements, organizations should engage in comprehensive interoperability testing. This helps verify that data is being shared seamlessly and securely across different systems and stakeholders. An Upcoming free CMS FHIR Connectathon is July 15-17th on this topic to learn more: https://ecqi.healthit.gov/registration-now-open-2025-cms-hl7-fhir-connectathon 

1. Staff Education and Training: It’s important to educate healthcare staff about the new data classes and elements included in USCDI V3. Ensuring that clinicians, IT professionals, and administrative staff understand these changes will help with smooth adoption.

1. Patient Communication: As patient-generated health data becomes more prominent in V3, organizations will need to develop new ways to collect, manage, and interpret this information, all while maintaining patient privacy and trust.

Looking Ahead:

The transition from USCDI V1 to V3 brings significant changes that impact how health data is shared, accessed, and utilized across the healthcare ecosystem. For organizations seeking to maintain CMS compliance, the transition involves updates to EHR systems, robust data governance practices, and a commitment to enhanced interoperability. While CMS 0057F is a payer centric regulation, there are greater impacts for implications to the broader healthcare data interoperability landscape. 

By staying ahead of these updates, healthcare providers can not only meet regulatory requirements but also improve care coordination, patient engagement, and overall healthcare outcomes. As we move forward into a more connected healthcare system, understanding and adapting to these changes will be crucial to success.

If you’re navigating the transition from USCDI V1 to V3 and ensuring CMS compliance, HealthLX, and our sister company, TESCHGlobal, have experts to be your trusted partner and lead you to compliance.