As part of the 2022 Final IPPS, page 24, "....We also are finalizing our provision that hybrid measures comply with the same certification requirements as eCQMs, specifically that EHR technology must be certified to the 2015 Edition Cures Update.”

We are looking for confirmation that the Hybrid Hospital-Wide Readmission Measure (CMS529) and the new Hybrid Hospital-Wide (All-Condition, All-Procedure) Risk-Standardized Mortality Measure (CMS844) would not need to go through the ONC certification process for the following capabilities for CQMs, since the hybrid measure is not a CQM:

170.315(c)(1): Clinical Quality Measures - Record and Export

170.315(c)(2): Clinical Quality Measures - Import and Calculate

170.315(c)(3): Clinical Quality Measures - Report 

Referencing a previous issue logged in May 2020 (this was answered as no certification needed for c1 -3, however, this was 1 year prior to the most recent rule).

CHM-46 Hybrid Hospital-Wide Readmission certification - Office of the National Coordinator for Health Information Technology (healthit.gov)

Thank you in advance for your guidance.