We respectfully request you to reconsider clarifications provided in CQM-8214 and CQM-8224, as they directly contradict the measure guidance, CQM-7417, and CQM-7413.
The measure guidance explicitly states: "The clinician who refers the patient to another clinician is the clinician who should be held accountable for the performance of this measure." CQM-7417 (November 2024) confirmed this by excluding Provider C from the denominator because they had a qualifying encounter but did not send a referral. CQM-7413 (November 2024) further clarified that "each clinician will need to ensure the referral loop is closed on the first referral for each patient," emphasizing individual provider responsibility for their own referrals.
However, CQM-8214 (September 2025) states that Provider B—who inherited a patient but did not place the referral and cannot even access it—is still held accountable for it. Similarly, CQM-8224 (September 2025) states that TIN B—who did not place any referral—is measured on TIN A's referral simply because they share an EHR. This creates an impossible contradiction: Provider C was excluded for not placing a referral, while Provider B and TIN B are included despite also not placing referrals.
We request you to amend CQM-8214 and CQM-8224 to align with the measure guidance and prior clarifications in CQM-7417/7413, confirming that only providers who place referrals should be held accountable for those referrals.