With the template update in CMS529v2 to use "Patient Characteristic Payer": "Medicare payer" instead of "Participation": "Medicare payer", is the expectation that the QRDA1 file will include more than on "Patient Characteristic Payer" template as the "Patient Characteristic Payer: Payer" (for supplemental data) should capture the primary payer for the visit. However, the "Patient Characteristic Payer: Medicare payer" (evaluated in the IPP) could evaluate primary, secondary, tertiary payers.

Additional question, with the removal of the payer timing evaluation, is it acceptable to identify a visit as having Medicare payer (regardless of the payer start/end time found in the EMR) as long it is determined that the Medicate payer was associated to the visit?