The narrative does not truly describe the scope of this IG. Please help readers and implementers by addressing the central issue: how does this IG define "cognitive status" and what kinds of information is it intended to cover.

Let's unpack this issue a little further.

What anchoring framework or standard terminology is used as the basis for defining the domain? Should it include assessments related to intellectual disabilities, learning disorders, or substance-induced impairments? What about the range of neuropsychological functional abilities/limitations? We recommend that both PACIO IGs anchor their labels and concept domains to the most well-established international framework for describing functioning and disability: the WHO's International Classification of Functioning, Disability and Health (ICF). The ICF framework will also be part of future ICD-11 which increases the validity of the framework and facilitates a stucture that can be used globally. Such a framework will be invaluable when trying to represent content from complex domains.

Further, "status" implies a singular axis of assessment. From both the ICF and the CMS-required assessment instruments, it is clear that several dimensions of functioning can be described (current performance, capability, goals, etc) and are related to both physiological, personal, and environmental factors. "Status" does not adequately capture this breadth. Rather, we propose (in conjunction with our recommendation to merge the IGs) that a simpler umbrella term of "functioning" be applied and that subdomain areas be identified as needed using the ICF's conceptual framework. For example, mental functioning. This is consistent with the current proposals in the USCDI.

Last, the scope of both IGs should be clarified with respect to the kinds of data (e.g. Resource types) that have been modeled. Rightly so, there has been heavy focus on Observations. Is it intended to only cover content contained in the CMS-required assessment instruments? Further, it is not clear whether representation of Conditions (diagnoses), Goals, Medications, Interventions, etc are in scope (now or in the future).