After reviewing both PACIO IGs (Functional Status and Cognitive Status), it is unclear why two separate IGs are needed. There is substantial overlap between the two implementation guides, and no discernable differences in the driving use cases. To the reader, it feels as though they are > 80% of the narrative is the same. Although a few parts (e.g. extensions) differ, the detail of the profiles and element bindings are basically the same. Splitting them into two IGs and having different profile names for subsections of content drawn from the same overall instrument (e.g. the CMS-required patient assessment instruments like MDS, OASIS, etc) imposes additional burden on implementers (and receivers). The rationale for splitting the IGs was not described in the IG. We propose merging the two IGs into a common core for functioning data, with the small number of domain-specific profiles that are needed being organized into subsections. Looking ahead to the other kinds of content being contemplated by the PACIO project, we believe this will be a more robust foundation.

Is there value in having two IGs? Please stongly consider merging the two IGs.