Description:

In our EHR, Encounter Diagnoses for measures such as PC-07 (CMS1028) and CMS996 are identified from multiple documentation sources, including but not limited to:

• Problem List entries
• Hospital Account (HAR)

In some cases, these sources may contain conflicting clinical documentation (e.g., a diagnosis present on the Problem List but intentionally excluded or corrected in the HAR).

Request:
Is it possible for CMS to provide clarification or allow a logic hierarchy structure where the Hospital Account (HAR)—which is finalized and coded—can take precedence over the Problem List or other sources when determining inclusion/exclusion in the measure?
 
We propose the following hierarchy (if supported by CMS logic specifications):
1.    Hospital Account (most authoritative/finalized)
2.    Problem List
 
This would align the measure logic more closely with how final diagnoses are coded and reduce noise from less definitive or outdated sources.