Thank you for the comment. Our team is currently updating the 2022 measure specifications. We plan on exploring this issue with the expert work group during the current annual update cycle and intend on seeking additional input from other stakeholders.

Patients could be incorrectly prescribed Satin medications if providers use CMS347 to guide their clinical decisions. This measure is required reporting for UDS as of 2019 and so could drive clinical decision making nation wide at Federally Qualified Health Centers. Submeasure 2 recommends Statin medications for patients with a diagnosis in the hypercholesterolemia value set 2.16.840.1.113762.1.4.1047.100 Riverside University Health System identified patients included in the measure solely based on diagnoses such as "LDL cholesterol greater than 129 mg/dL". These patients should NOT be on Statin medications according to American Heart Association guidelines. We verified with Intelligent Medical Objects (IMO - the primary vendor for diagnosis and diagnosis coding content for Epic customers in the US). That the E78.00 ICD-10 code as well as some of the SNOMED codes from the hypercholesterolemia value set are defined so as to include diagnoses for generally elevated LDL that do not necessarily require treatment by a Statin Medication. We believe the hypercholesterolemia valueset needs to be removed from submeasure 2, at least until such a time as more specific coding for familial hypercholesterolemia is available.