As a CMS MIPS vendor, we are unable to attribute results for certain eCQM measures because the CQL is constructed in a manner that includes “exists” for the data elements which only return Boolean values of 1 for true or 0 for false, rather than returning the data for that element.  Below, I have outlined how each measure is currently constructed in the CQL with proposed revisions (using 2023 measure versions) that would enable us to implement our attribution.  I am hoping we can get this resolved for 2024.

CMS645v6

Current

Initial Population

"Patient is Male"

  and "Has Qualifying Encounter"

  and exists "Order for 12 Months of ADT During Measurement Period"

Has Qualifying Encounter

exists ["Encounter, Performed": "Office Visit"] Encounter

  where Encounter.relevantPeriod during "Measurement Period"

Proposed

Initial Population

"Patient is Male"

  and exists “Qualifying Encounter”

  and exists "Order for 12 Months of ADT During Measurement Period"

Qualifying Encounter

["Encounter, Performed": "Office Visit"] Encounter

  where Encounter.relevantPeriod during "Measurement Period"

CMS646V3

Current

Initial Population

"First Bladder Cancer Staging Procedure during Measurement Period" is not null

  and "Has Most Recent Bladder Cancer Tumor Staging is Ta HG, Tis, T1"

  and "Has Qualifying Encounter"

Has Qualifying Encounter

exists ["Encounter, Performed": "Office Visit"] ValidEncounter

  where ValidEncounter.relevantPeriod during "Measurement Period"

    and ValidEncounter.class !~ "virtual"  

Proposed

Initial Population

exists ( "Bladder Cancer Diagnoses" )

  and "Has Most Recent Bladder Cancer Tumor Staging is Ta HG, Tis, T1"

  and exists "Qualifying Encounter"

Qualifying Encounter

["Encounter, Performed": "Office Visit"] ValidEncounter

  where ValidEncounter.relevantPeriod during "Measurement Period"

    and ValidEncounter.class !~ "virtual"

CMS771v4

Current

Initial Population

( "Patient is Male" )

  and "Has Qualifying Encounter"

  and "Has Qualifying BPH Diagnosis"

  and "Urinary Symptom Score Within 1 Month after Initial BPH Diagnosis" is not null

  and "Urinary Symptom Score 6 to 12 Months After Initial BPH Diagnosis" is not null

Has Qualifying Encounter

exists ["Encounter, Performed": "Office Visit"] ValidEncounter

  where ValidEncounter.relevantPeriod during "Measurement Period"

    and ValidEncounter.class !~ "virtual"

Proposed

Initial Population

( "Patient is Male" )

  and exists “Qualifying Encounter”

  and "Has Qualifying BPH Diagnosis"

  and "Urinary Symptom Score Within 1 Month after Initial BPH Diagnosis" is not null

  and "Urinary Symptom Score 6 to 12 Months After Initial BPH Diagnosis" is not null

Qualifying Encounter

["Encounter, Performed": "Office Visit"] ValidEncounter

  where ValidEncounter.relevantPeriod during "Measurement Period"

    and ValidEncounter.class !~ "virtual"