Hello-

I have a question about how much flexibility EHR vendors may exercise with regard to handling value sets in their calculation of CQMs (and still get certified).

For some of the MU2 CQM value sets, codes are not included that can would reflect the Quality Data Element to which the value set corresponds, and would be highly likely to exist in a patient record.

Here is an example:

In measure 153, "Chlamydia Screening for Women", the QDE "Diagnostic Study, Order: Diagnostic Studies During Pregnancy" represents procedures that are only done on pregnant women. This QDE is used in the logic for this CQM as one of several indicators that a woman has been noted to be sexually active (and thus belongs in the denominator population).

Thus QDE is tied to the value set "Diagnostic Studies During Pregnancy Grouping Value Set" (OID = 2.16.840.1.113883.3.464.1003.111.12.1008), which consists of 599 codes, ALL from LOINC, including some pretty esoteric ones (like the LOINC for "Fetal weight estimated from Abdominal circumference and Biparietal diameter and Femur length by method of Hadlock 1984 (US)")

Of course, there are many codes from other coding systems (particularly CPT and SNOMED) that legitimately represent a "diagnostic study during pregnancy", and in actual practice are more likely to be found in patient data in an EHR than the 599 LOINC codes included in the value set, for instance, SNOMED 268445003 ("ultrasound scan - obstetric")

It is my understanding that neither CMS nor ONC has any control over the contents of the value sets; Rather, these are under the exclusive control of the measure developer/steward.

Thus, I have two specific questions:

1. May an EHR vendor consider additional codes not included in a value set in their calculation of a CQM, and still get certified?

2. May an EHR vendor provide users with the ability to record data at the level of the QDE itself, and use that in their calculation of a CQM, and still get certified? In the example above, for instance, the EHR vendor might provide a way for a user to simply record, as structured data, that a "diagnostic study during pregnancy" was done on a particular date, and then treat that in the CQM calculation as if one of the codes from the value set were found.

I hope these questions are clear, and thank you in advance for your response.