In 2012 in support of meaningful use requirements for electronic clinical quality measures, we built a new tool to support calculation of eCQMs that features the following:

• An eMeasure framework that semantically normalizes data to create an EHR agnostic repository
• Automatically consumes and runs eMeasure rules with no measure specific coding that uses the existing framework
• Report / Submit on any eMeasure that uses existing data and rules frameworks

This solution was successfully deployed on over 120 client sites having three different clinical systems enabling client providers to successfully report since 2014. We appreciate the opportunity to provide CMS feedback on the feasibility and usability of the new CQL standard given our extensive experience in this area.

See the attached document which contains feedback in each of the categories requested for Vendor Participation in CQL Evaluation CMS 111 and CMS 31.