The eMeasure specification defines criterion, but does not define how to implement it. Using location information to identify ICU encounter may be one of many possible paths for measure implementation. For example, SNOMED CT has code sets for "Admission to intensive care unit" and "patient transfer to intensive care unit", neither code has an associated location attribute. For eMeasure specification, what is the rationale regarding why an ICU Encounter itself cannot represent the "ICU encounter" concept? If it's true, then should we also change all ‘Inpatient Encounter’ to ‘Inpatient Encounter (attribute: Hospital or Ward Location)’? Another possibility is using location of the ICU encounter/arrival time to ICU location. However, if the issue is about the consistency of ICU encounter representation in all hospital measures, it should be considered. For harmonization, the ICU encounter should be modeled and represented consistently across all Hospital measures. While the criterion does not tell you how to implement the ED visit, it does define the type of data we are looking for (I.e., encounter, performed). So if an EHR is not using this construct, there may be issues. Again, we need to be careful on how we go about saying that “this can be anything” if we want to achieve standardization in eMeasurement. We don’t feel this issue can be resolved without input from a number of vendors and providers regarding the modeling of the ICU stay (encounter vs. location); we may need to model it both ways if there isn’t consensus, or opt for the more prevalent scenario. We do acknowledge the concern about 1) distinct ways of modeling the same concept in different measures; and 2) modeling the ICU encounter may pose a feasibility issue. These concerns should be taken into consideration for the next version of the eSpecifications.