July 16, 2001

The Honorable Tommy G. Thompson
Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201

Dear Secretary Thompson:

This letter transmits the most recent report of the National Committee on Vital and Health Statistics (NCVHS), “Classifying and Reporting Functional Status”, which was approved by the full Committee at its June 27-28, 2001 meeting. The report is the culmination of an 18-month long review by the NCVHS Subcommittee on Populations, which included hearings and consultations with clinicians, researchers and other data users.

The World Health Organization (WHO) newly revised International Classification of Functioning, Disability and Health (ICF) is described in the report as a promising approach to coding functional status information in computerized patients records and standardized data sets. Functional status is one of the elements previously recommended by the NCVHS as a core health data element for enrollment and encounter records. At hearings organized by the Subcommittee on Populations in 2000, representatives of health professions and health care provider organizations testified on the utility and feasibility of using the ICF in connection with enrollment forms, encounter forms, and other health administrative records included in the HIPAA transaction standards. The information also has implications for national and international health statistics.

The NCVHS recommendations that were developed are intended to help bring about three basic and necessary steps: 1) broad agreement on the importance of collecting functional status information; 2) selection of a code set for functional status data in standardized records; 3) selection and testing of a code set for these purposes.

The National Committee recognizes the importance of functional status information in clinical care, public health practice, policy, and administration. The next task is to find an effective way to incorporate this information into standardized records, and to evaluate the ICF as a possible mechanism for that purpose. Although gathering functional information through administrative data offers important opportunities for management and oversight of health care quality, significant questions remain about the feasibility and costs of collecting these data. These practical questions must be addressed before widespread reporting of functional status should begin.

NCVHS urges the Department to exercise leadership in this effort and to give it the priority it deserves, in continued collaboration with the World Health Organization. The Committee would welcome annual status reports from the Department on this project, beginning in 2002. Finally, the Committee offers its advice and enthusiastic support for all efforts aimed at enriching clinical and administrative data with functional status information.



John R. Lumpkin, M.D., M.P.H.

Co-Chairs, HHS Data Council