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Solution:
FAQ9062 has been published on the CMS website for CMS64v3. Changes for denominator 2 will be addressed at the next annual update.
Impact:

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CMS 64 contains criteria that are impossible to meet, due to the use of a grouping of AND operators that should be OR statements.

Within the Denominator 2 section of this measure, the spec states that a patient must have a count >= 3 of the 4 listed Risk Factors AND a count = 2 of the same 4 Risk Factors.

CMS 61 also includes looking for these Risk Factors but the logic in that measure states that patients can have either a count >=3 of the Risk Factors OR a count = 2 Risk Factors.

Due to this, I'm assuming CMS 64 has the incorrect operator for this portion of the Denominator 2.

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CMS 64 contains criteria that are impossible to meet, due to the use of a grouping of AND operators that should be OR statements. Within the Denominator 2 section of this measure, the spec states that a patient must have a count >= 3 of the 4 listed Risk Factors AND a count = 2 of the same 4 Risk Factors. CMS 61 also includes looking for these Risk Factors but the logic in that measure states that patients can have either a count >=3 of the Risk Factors OR a count = 2 Risk Factors. Due to this, I'm assuming CMS 64 has the incorrect operator for this portion of the Denominator 2.