We are working with our vendor to pull the appropriate lab values for each of the hybrid measures.  We are finding we are 'missing' values because some of our patients are admitted to observation past the 24-hour window of lab value applicability relative to the inpatient admit date time.  Let me explain through an example.

85 year old patient arrived in our emergency department on 9/15/23 at 18:32. 

Applicable labs were drawn/resulted 9/15/23 at 19:15.

Patient was admitted to observation status 9/15/23 at 23:49.

Another set of applicable labs were drawn/resulted 9/16/23 at 07:09.

Patient was admitted to inpatient status on 9/17/23 at 11:05.

Patient spent approximately 36 hours in observation prior to inpatient admission.  This is allowed under the Medicare 48 hour observation rule.

However, because the labs do not fall within 24 hours prior to the inpatient admit date time stamp, none of the labs drawn are included in our QRDA file.

Per the specifications:

1. If the patient has values captured prior to admission, for example from the emergency department, pre-operative, or other outpatient area within the hospital, the logic supports extraction of the FIRST resulted vital signs and laboratory tests within 24 hours (1440 minutes) PRIOR to the start of the inpatient admission. All clinical systems used in inpatient and outpatient locations within the hospital facility should be queried when looking for core clinical data element values related to a patient who is subsequently admitted.

We could subsequently incur a payment decrease because we are not able to meet the 90% submission needed for lab values, even though they were drawn on the qualifying inpatient encounter.

Please advise.