Benefits of a UDI System
April 23, 2026 Update:
The Centers for Medicare & Medicaid Services (CMS) has issued a proposed rule that would establish a Unique Device Identifier (UDI) measure under the Public Health and Clinical Data Exchange objective of the Medicare Promoting Interoperability (PI) Program.
Under this proposal, developed in partnership with the FDA, eligible hospitals would attest “Yes” or “No” to whether they used certified electronic health record technology (CEHRT) to capture the complete UDI for each implantable medical device subject to UDI requirements.
Capturing UDI data within electronic health records (EHRs) is a practical step toward realizing the intent of the UDI system—advancing patient safety. Accurate and consistent documentation of UDIs enables precise identification of devices used in patient care. This, in turn, supports the generation of reliable real-world data (RWD) and real-world evidence (RWE), strengthening the ability to monitor device safety and effectiveness over time.
The proposed rule is available here: https://www.federalregister.gov/documents/2026/04/14/2026-07203/medicare-program-hospital-inpatient-prospective-payment-systems-for-acute-care-hospitals-ipps-and.
Now fully implemented, the Unique Device Identification System offers a range of benefits to industry, the FDA, consumers, health care providers and health care systems by:
- Allowing more accurate reporting, reviewing and analyzing of adverse event reports so that problem devices can be identified and corrected more quickly.
- Reducing medical errors by enabling health care professionals and others to more rapidly and precisely identify a device and obtain important information concerning the characteristics of the device.
- Enhancing analysis of devices on the market by providing a standard and clear way to document device use in electronic health records, clinical information systems, claim data sources and registries. A more robust postmarket surveillance system can also be leveraged to support premarket approval or clearance of new devices and new uses of currently marketed devices.
- Providing a standardized identifier that will allow manufacturers, distributors, and health care facilities to more effectively manage medical device recalls.
- Providing a foundation for a global, secure distribution chain, helping to address counterfeiting and diversion and prepare for medical emergencies.
- Leading to the development of a medical device identification system that is recognized around the world.
Adoption in Health Care Systems
The final UDI rule provides the regulatory framework for implementation of a UDI system by the device industry. The benefits offered by such a system will only be fully realized with the adoption and use of UDIs by manufacturers, distributors, payers, providers, patients, health care systems and other stakeholders with important roles to play throughout the medical device lifecycle.
A key element for achieving these benefits requires working collaboratively with Federal partners and other external stakeholders to promote UDI incorporation into electronic health information. FDA also is collaborating with the Engelberg Center for Health Care Reform at Brookings to develop a roadmap for the successful adoption and implementation of UDI throughout the health care systems, which will convey the value of UDI implementation, guide relevant stakeholders in addressing key challenges, and serve as a foundation for policies supporting UDI adoption.
In 2012 and 2013, the FDA supported an 18-month demonstration project with Mercy, a large U.S. health care system, related to the adoption of UDI in the clinical setting. This project had three aims:
- To implement a coronary artery stent UDI-based surveillance system in the electronic health record (EHR) in a multi-hospital system.
- To identify obstacles to implementation of the UDI Roadmap produced by the Medical Devices Epidemiology Network (MDEpiNet) Think Tank and characterize the effectiveness of interventions to overcome them.
- To assess the validity and utility of data obtained from the EHR and incorporated UDIs for purposes of post-market surveillance.
The final report "Advancement of Innovative Methodologies and Medical Device Specific Infrastructure for Evidence-Based Regulatory Science and Public Health Surveillance" summarizes the identified challenges and opportunities of implementing UDI in a large hospital system.
In addition, the Pew Charitable Trusts developed a video highlighting the benefits of UDI implementation in Mercy. In the video, a cardiologist, supply chain executive, and nurse discuss Mercy’s efforts, which serve as a model for health care professionals and health systems looking to utilize and benefit from the UDI system.
UDI Inclusion in Health Care Claims
In July 2023, the FDA sent a letter to the National Committee on Vital and Health Statistics (NCVHS) in response to NCVHS’ recommendation to HHS not to adopt the updated X12 standard (Version 008020). The X12 standard, which is used for electronic exchange of health care claims transactions, has been updated to include the ability to capture and transmit the Device Identifier portion of the Unique Device Identifier (UDI-DI). Read the FDA response to NCVHS.