​Thank you for your question about the Numerator for CMS122v9, Diabetes: Hemoglobin A1c (HbA1c) Poor Control (> 9%). The current logic looks for the last HbA1c Laboratory Test performed during the measurement period and is looking for a numerical value. The measure logic would not recognize the message sent back from a lab, "TEST NOT PERFORMED". The measure treats a numerical value as poor control because the test performed should have a result so that the patient's HbA1c value is known. It would be expected that if a lab test came back with no result, a follow up test should be performed.

The guidance for the measure states that the patient is numerator compliant if any of the following is true: • Condition 1: most recent HbA1c level >9%, • Condition 2: the most recent HbA1c result is missing, • Condition 3: there are no HbA1c tests performed and results documented during the measurement period. It goes on to state that “If the HbA1c test result is in the medical record, the test can be used to determine numerator compliance.” Consider the following: Scenario 1: Encounter and A1c on 01/15/2021 Value is 6.5 Encounter on 04/15/2021. A1c is ordered, Blood draw performed. Lab loses the specimen Lab sends back result as: TEST NOT PERFORMED , with a Comment: Unable to perform testing due to a laboratory error. Charges adjusted as applicable Scenario 2: Encounter on 04/15/2021. A1c is ordered, Blood draw performed. Lab loses the specimen Lab sends back result as: TEST NOT PERFORMED , with a Comment: Unable to perform testing due to a laboratory error. Charges adjusted as applicable Our EHR measure logic reads Scenario 1 as “MET” since it is interpreted as a test that WAS performed, but the result missing. My question: Would it not be appropriate to internally strip/ignore this test that did not occur thereby allowing the logic to evaluate the actual most recent A1c? Do the specs require us to report a Lab that was not performed as Laboratory Test, Performed ? In Scenario 1, since in point of fact no A1c was performed, this would allow the logic to disregard the 04/15 date, and look back to the value on 01/15/2021 where the A1c WAS performed during the performance period, and the result will be NOT MET since the value is <9 Note that in Scenario 2, the measure intent will be fulfilled, since the outcome would be MET with Numerator Condition #3 – no tests performed. This approach would prevent the group (or individual EC) from being penalized for a lab error, while still requiring the A1c during the performance year. Please advise.