The PACIO Cognitive Status and Functional Status IGs are intended to be used for the exchange of observation data collected through the use of assessment tools, instruments, screens, or other types of structured resources in various healthcare settings and home-and community-based services. Therefore, we believe the PACIO IG profiles should be based on the Observation resource instead of the US Core Observation Lab profile which mainly concerns with lab results and requires a category code of ‘laboratory’.

We request an exception to the requirement to use a US Core Profile on Observation for this specific use case.