My question is related specifically to the IQR submission threshold requirement and the impact to APU. During the voluntary reporting periods there have been several tickets opened related to specification expectations (around CCDEs), concerns related to usability and issues within feedback reports. (i.e. reported failures for patients not expected in the population (<65), confusion on output of reports (individual CCDE passing but overall failure of requirement)) . We will be 3/4 through the mandatory submission period before these items can we retested by facilities (and/or with the help of vendors). 

Additionally, the specification logic may have some vulnerabilities related to CCDEs for specific populations that are later expected to be excluded. We understand that some of the index admission types will be excluded but that does not happen until after the submission threshold is calculated (CHM-215). Its possible that some of these scenarios would result in failure of the CCDE requirement for specific records. For example, a patient that left AMA may not have all expected labs. 

We understand the need to submit the data to ensure participation. However, has there been any consideration given to the submission threshold requirement penalty? As the measure developer and CMS continue to work through any known issues as well as those unforeseen at this time.  

The Hybrid measures may not be considered "eCQMs". However, because of the discrete data capture caveats they are susceptible to many of the same issues seen with the inpatient eCQMs. The inpatient eCQMs have been vetted for the better part of a decade and are still evolving to ensure accuracy.