Both PHD and PoCD medical devices using 11073 20601 and 11073 10201 have fields shared across most implementations that cannot be represented in FHIR without extensions. These properties are ubiquitous so it seems that there should be a means of expressing this in the DeviceComponent without extensions.

As examples of these properties there are static time properties, certification information, and regulation status.

It would also be advantageous to introduce an element that is extensible in a manner similar to the component element of the Observation. I would propose a deviceProperty data type consisting of a CodeableConcept and a value[x] field. 11073 has already defined reference ids for several device properties that could be expressed using this element. This approach would allow for the expression of additional properties by introducing new codes.