The final rule states the following:

After consideration of the public comments received, we are finalizing the "sampling–all payer" option for patient-level data. This submission characteristic will only include patients that meet the denominator criteria of the CQMs that the eligible hospital or CAH selects to report to CMS and only the data elements listed in the CQM and transmission specifications for those patients would be sent to CMS.

Does this qualify as “prescriptive guidelines” as referenced in the HL7 QRDA I specification? Quote:

Often times, a quality program implementing QRDA will provide prescriptive guidelines that define the exact rules for which eMeasures to reference in a QDM-based QRDA Cateogyr (sic) I instance, or the exact triggers for sending a QRDA document. Where such prescriptive guidelines exist, they take precedence over the more general guidance provided here.

If so, does that mean that EHRs should only send QRDA I documents for patients that meet the denominator criteria and that meeting the initial patient population criteria is not sufficient?

There seems to be some general confusion between the use of “initial patient population” and “denominator” and we want to make sure it’s clear.