CMS154v12 - "Appropriate Use of Antibiotics for URIs" attempts to measure inappropriate use of antibiotics for viral URIs. The measure appropriately excludes people already on antibiotics prior to the URI visit, and at least in theory, excludes patients who are prescribed antibiotics for a bacterial infection.

During routine measure validation - we found two instances where patients had URI symptoms AND positive strep tests. In these cases, the treating physician coded the visits with (1) strep pharyngitis and (2) URI, and in the other visit (1) tonsillitis and (2) URI. Both of these patients were scored as UNMET, antibiotic prescribed. We initially thought our EHR vendor had incorrectly implemented this measure, but upon review - the problem was in the value set. Many bacterial infections were listed as "competing conditions" in the value set...but not strep pharyngitis and not tonsillitis.

The solution is to fix the value set!  We found two examples, I don't know how many other valid bacterial infections are missing from the value set - but I would guess there are others.  

Assuming that strep pharyngitis and tonsillitis were the only two competing conditions missing from the value set, I think mapping one ICD-10 code to another code is an inherently unsafe solution - would it be possible that these remapped codes may exist outside of an eCQM report for one measure - and then inappropriately lead public health to an erroneous conclusion as to a new epidemic (here, of scarlatina).

And that aside, our vendor said no.  They build and certify their eCQMs with some options for mapping - typically permitting varying workflows that capture structured documentation in different ways... but not so with the Problem list, Diagnosis List, Med List and Allergy list.