Stage 1 Core Criteria for Eligible Hospitals or Critical Access Hospitals (CAHs) to Record Demographics - Preliminary Cause of Death

This web page provides background for the Meaningful Use requirement to record "preliminary cause of death" as part of the overall objective to record selected patient demographics in the Electronic Health Record (EHR). "Cause of death" is one of the data items collected on the Death Certificate as part of the California vital records system that is overseen by the California Department of Public Health (CDPH). While Preliminary Cause of Death is not the same as Cause of Death, CDPH would like to provide information to assist in clarifying the differences.

The Centers for Medicare and Medicaid Services (CMS) EHR Incentive Program Final Rules references the Stage 1 Core Set Objective as below:

Section 495.6(f)(6)(i) Objective. Record all of the following demographics;

(A) Preferred language.

(B) Gender.

(C) Race.

(D) Ethnicity.

(E) Date of birth.

(F) Date and preliminary cause of death in the event of mortality in the eligible hospital or CAH.

Section 495.6(f)(6)(ii) Measure. More than 50 percent of all unique patients admitted to the eligible hospital’s or CAH’s inpatient or emergency department (POS 21 or 23) have demographics recorded as structured data.

CDPH Background For Preliminary Cause of Death:

1) What is Preliminary Cause of Death? Is it the same as Cause of Death?

The Preliminary Cause of Death is not the same as the Cause of Death that is entered into the Death Certificate. The Preliminary Cause of Death is entered into the patient’s medical record as part of the provider’s note that a patient has expired. In contrast, the Cause of Death is one of the fields filled out by the provider when completing a Death Certificate, which is separate from the patient’s medical record.

Important Note: Recording the Preliminary Cause of Death in an EHR does not fulfill the physician's duty to record Cause of Death in the medical and health section of the Death Certificate, as required by California Health and Safety Code Section 102800.  

To clarify, Preliminary Cause of Death is explained in the CMS Final Rules for the EHR Incentive Program, Page 44341:

"When a patient expires, in the routine hospital workflow, a clinician evaluates the patient to pronounce the patient’s death. The clinician typically documents in the patient’s chart, the sequence of events leading to the patient’s death, conducts the physical exam and makes a preliminary assessment of the cause of death. We are requiring that eligible hospitals record in the patient’s EHR the clinical impression and preliminary assessment of the cause of death, and not the cause of death as stated in any death certificate issued by the Department of Health or the coroner’s office."

2) How should Preliminary Cause of Death be recorded in the EHR?

There are no standards for recording Preliminary Cause of Death. Providers unfamiliar with recording Preliminary Cause of Death may find the guidelines for documenting Cause of Death to be useful. The Centers for Disease Control and Prevention provide both a summary and detailed instructions on recording Cause of Death.

3) Does Preliminary Cause of Death need to be updated in the EHR if Cause of Death is changed?

According to this CMS answer, Preliminary Cause of Death does not need to be updated in the EHR once recorded, even if the Cause of Death changes due to additional information from the Coroner's Office, Medical Examiner, or CDPH.

4) Does Preliminary Cause of Death need to be reported to CDPH?

Preliminary Cause of Death does not need to be reported to CDPH. Only Cause of Death is reported to CDPH through the California Electronic Death Registration System.

5) How is Preliminary Cause of Death or Cause of Death used by CDPH?

CDPH does not use Preliminary Cause of Death information; however, Cause of Death data is analyzed in many reports, such as Death Data Trend Summary reports.