The 2015 eCQMs requiring a negation for a medication do not comply with QRDA-I Release 3 and do not follow the logic guidance version 110 published May 2015. The measures need to be updated to reflect the logic in QRDA-I Release 3. The following example illustrates the changes needed.

Stroke-2 Discharged on Antithrombotic Therapy

Current 2015 specifications refer to the ingredient specific medication in the negation logic;

• Denominator Exceptions =
OR: Union of:
 "Medication, Discharge not done: Medical Reason" for "Antithrombotic ingredient specific"
 "Medication, Discharge not done: Patient Refusal" for "Antithrombotic ingredient specific"

This is NOT compliant with section 5.2.3.1 (pg. 30) of the CMS Implementation Guide for Quality Reporting Document Architecture Category I and Category III Eligible Professional Programs and Hospital Quality Reporting (HQR) Supplementary Implementation Guide for 2016 https://www.cms.gov/Regulations-and Guidance/Legislation/EHRIncentivePrograms/Downloads/QRDA_2016_CMS_IG.pdf

The logic should be similar to this;
• Denominator Exceptions =
OR: Union of:
 "Medication, Discharge not done: Medical Reason" for null Flavor="NA" sdtc:valueSet=" 2.16.840.1.113762.1.4.1021.8"
 "Medication, Discharge not done: Patient Refusal" for nullFlavor="NA" sdtc:valueSet=" 2.16.840.1.113762.1.4.1021.8"

This is also explained logic guidance guide included with the 2015 specifications (pg. 24-25);

A negation attribute may be used to identify situations where an action did not occur or was not observed for a documented reason. Prior to the April 2014 eCQM release, implementers representing that a therapy was not done due to a medical, patient, or system reason were expected to use the same detail-level value sets for the noted “not done” therapy. This raised issues given that for medications, it was rare that a specific drug was noted as “not given.” With the April 2014 release, documentation of “medication, ordered not done” and “medication, discharge not done” are now associated with ingredient-level RxNorm value sets so that specific prescribable drugs are no longer used to document these “not done” events. For the May 2015 release, the QRDA-I Release 3 and CMS Implementation Guide utilize null values to replace a specific code associated with a value set when describing activities that were negated or “not done.” This approach is intended for use with all datatypes that use negation to describe activities “not done,” unlike the previous approach limited to medications that required creating new value sets with "general concepts”. This approach does not change the expression of negation in the HQMF; however, it does require an HL7 nullFlavor code to be used instead of a specific code from the value set that is associated with these activities in the QRDA-I file. The intent of the null flavor in this context is to specify that ALL the activities in the value set were intentionally not done, not that a single activity was not done or that it is not known why that activity was not completed. It is not appropriate for users to certify that an activity was not done using negation unless the provider intentionally did not order or perform the activity in question and documented a justification why that was the case.

Could we be given a hard-date when the eMeasure must rewrite their specifications to meet the current QRDA-I guide? In our opinion, the current specifications violate the logic in QRDA-I Release 3 therefore the applicable measures are not valid. Please advise.