For consideration:

Hospitals that have psych or rehab (etc) units where some patients are billed under a psych facility CCN and some are billed under the ACH CCN are unable to exclude the psych CCN billed encounters from both Hybrid and eCQM populations.

In these cases, the psych CCN billed encounters are to be excluded (this has been communicated via CMS tix, FAQs and in presentations). The problem is that this exclusion is not written into the measure logic and hospitals (and vendors) have to manually exclude the psych CCN billed encounters or potentially create separate logic (which may be outside of certification compliance).

For future measure consideration, can psych encounters (and other non-acute encounters) be excluded from the IP such as is seen in AKI for OB dx:
"Encounter with Creatinine and without Obstetrical Conditions
or Exclusion populations via statements similar to VTE 1 exclusion:  union "Encounter with Principal Diagnosis of Mental Disorder or Stroke"?

Including the psych CCN billed encounters is going to impact measure results negatively, increase the size of the files submitted and increase burden on hospitals (with decreased opportunity for improvement given the skewed results). In addition, there is risk of failing the hybrid measure threshold requirements.

Thank you.