USCDI v3 Validator - Disability and Functional Status Errors

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Braeden Rai

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Jan 7, 2026, 10:33:59 AM (3 days ago) Jan 7
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Hello,

While testing the b1 ambulatory and inpatient scenarios, we validated documents for patients that have disability and functional status documented. (Attached is a document that has both of these codes sent.) However, the validator returned an error saying that these statuses were missing from the document. This seems to be an issue with the validator, would you be able to confirm that?

b1 sample 1 for both ambulatory and inpatient (Alice Newman and Rebecca Larson) have this issue, at least.

Thanks, 
Braeden
Rebecca17test

Shuisheng Wang

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Jan 7, 2026, 4:27:11 PM (2 days ago) Jan 7
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Hi Braeden,
Following two error messages indicated that CCDA entries of Disability Status Observation & Functional Status Observation were missing in your XML file.  Hope this helps.

Result Description: The scenario requires Patient's Disability Status Observation data but the submitted C-CDA does not contain Disability Status Observation data.

Result Description: The scenario requires Patient's Functional Status Observation data but the submitted C-CDA does not contain Functional Status Observation data.


Miles Williams

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Jan 8, 2026, 2:41:46 PM (2 days ago) Jan 8
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I think we are right to send these as Assessment Scale Observations instead of Functional Status and Disability Status Observations based on the Companion Guide:

6.2.8.1 Functional Status 
A clinician, or caregiver, may record the functional status of a patient (e.g., mobility status, activities of daily living, self-care status) using a formal assessment tool, or a simple assertion. When a clinician uses a formal instrument, such as the Glasgow Coma scale, systems are encouraged to use the Assessment Scale Observation to group a series of Assessment Scale Supporting Observations. See the approved Functional Assessment - Glasgow Coma example. Note, the best practice is to include the final 'score' in both the Assessment Scale Observation/value in addition to an individual Assessment Scale Supporting Observation. Use of the prior Functional Status Organizer and Functional Status Observation is discouraged since the it promotes inconsistent generation of an Organizer/Observation when a generic Assessment Scale Observation/Assessment Scale Supporting Observation is sufficient. In a future release of C-CDA, Structured Documents will deprecate these legacy templates. In certain situations a clinician may make a judgement about a patient's physical function. The Functional Status Observation is the appropriate place to record this judgement. See approved Functional Impairment example.  

6.2.8.2 Disability Status 
A clinician can use the new Disability Status Observation to assert a specific concern about a patient. A prior HL7 standard, the electronic initial case report (eICR), created a Disability Status Observation template constrained to 8 concepts (see VSAC (log-in required): Disability Status). The eICR project is restricted to report "minimum necessary” data needed for public health case reporting. The new Disability Status Observation is not limited to these 8 concepts, and adds the ability to include an Assessment Scale Observation/Assessment Scale Supporting Observation. 

Because both sections suggest that the Assessment Scale Observation (2.16.840.1.113883.10.20.22.4.69) is permitted (and encouraged for formal assessment tools) can we remove the requirement that the observations be Functional and Disability Status Observations (2.16.840.1.113883.10.20.22.4.67 & 2.16.840.1.113883.10.20.22.4.505)? 
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