These 2 patient characteristic codes are handled differently than other patient characteristic code sets (ie payer) that are included in the human readable in the terminology and QDM data elements even though they are not used in the logic but are required for reporting. What is the intent to handle these 2 codes only going forward?

 There are inconsistencies regarding these two DRCs noted within the supporting implementation documents.

The Electronic Clinical Quality Measure Logic and Implementation Guidance Version 2.0:

Page 17 Section 5.2 “These codes, such as birth date and death date, are included directly with the measure logic and in the terminology section of the HQMF.” In the preview specifications the LOINC code 21112-8 was included in at least some of the specifications (CMS 75, 82 and 349) in the vocabulary section of the HTML and were removed in the final specification. This seems to be saying these 2 codes and others like it will be found in the terminology section of the human readable but they are not included.

Page 24 Section 5.14 Patient Characteristics Birthdate and Patient Characteristic Expired: states that DRCs will be included in the measure logic and the new terminology section with 2 exceptions which are the birth date and expired.

The Guide for Reading Electronic Clinical Quality Measures (eCQM) Version 4.0: refers to QDEs referencing either a value set or a single code. There is no reference to DRCs in section 3.2.3 Value Set Authority Center, which does have DRCs available for download in excel and includes all except for the 2 defined in QDM 5.3 Annotated.

The need to go to additional documents for codes increase the risk of missing codes in analysis and adds burden. Shouldn’t these codes (and any future codes) that are defined within the QDM as fixed to a specific code also be included in the terminology section and in the QDM data elements section if they are category codes such as Patient Characteristic data elements with OIDs?