Value Set defining observation status for CMS 529 is inconsistent with measure intent.

The Guidance section for the Specifications for hybrid measure CMS 529 includes these statements.
“This logic guides the user to extract the FIRST resulted HWR-specific CCDEs for all Medicare FFS and MA hospitalizations for patients age 65 or older (Initial Population) directly admitted to the hospital or admitted to the same facility after being treated in another area such as the emergency department or hospital outpatient/same day surgery location.

“All clinical systems used in inpatient and outpatient locations within the hospital facility should be queried when looking for CCDE values related to a patient who is subsequently admitted.

”For weight, the logic supports extraction of the FIRST resulted vital sign recorded during the hospitalization, which may be prior to, or during admission.”

However, the Value Set that defines the areas of the hospital that are captured for outpatient, “Outpatient Surgery Service” 2.16.840.1.113762.1.4.1110.38 includes only codes related to surgery. This is not consistent with the intent of the measure that states that “all clinical systems used in inpatient and and outpatient locations within the hospital facility should be queried.”

Isn’t a broader Value Set needed to capture times when patients have Outpatient status?

https://ecqi.healthit.gov/sites/default/files/ecqm/measures/CMS529v5.html