Clarification on whether a data aggregation vendor may populate a derived/default ResultValueText when source data is null for imaging results (eCW PHA, 2026 reporting)

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    • Type: EC eCQMs - Eligible Clinicians
    • Resolution: Unresolved
    • Priority: Moderate
    • Component/s: None
    • None
    • Wendy Lynch
    • 5743446183
    • IMAT Solutions
    • CMS0125v13
    • Hide
      IMAT, acting as a data aggregation vendor for our client, is being asked to populate a value in ResultValueText for imaging/x-ray results where the source (RAW) data does not contain a result value.

      Specifically:

      Source data: ResultValueText is null/blank

      Requested transformation: populate with static value
      "Result Resides in EMR"

      Without CMS guidance, this creates risk that:

      The data may no longer be considered source-representative

      IMAT may be altering clinical content beyond aggregation/normalization scope

      Submissions could fail compliance, audit, or validation checks

      This introduces a non-source, derived value into the clinical data payload.
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      IMAT, acting as a data aggregation vendor for our client, is being asked to populate a value in ResultValueText for imaging/x-ray results where the source (RAW) data does not contain a result value. Specifically: Source data: ResultValueText is null/blank Requested transformation: populate with static value "Result Resides in EMR" Without CMS guidance, this creates risk that: The data may no longer be considered source-representative IMAT may be altering clinical content beyond aggregation/normalization scope Submissions could fail compliance, audit, or validation checks This introduces a non-source, derived value into the clinical data payload.

      A requirement from the client requests:

      • Populating ResultValueText with a static value:
        "Result Resides in EMR"

      However:

      • This value does not exist in the RAW/source data
      • IMAT would be introducing this value during transformation

      IMAT’s role is typically limited to:

      • Data aggregation
      • Normalization
      • Format standardization

      We are seeking CMS guidance to determine whether this requested transformation is compliant/permissble.

            Assignee:
            AIR EC eCQM Team
            Reporter:
            Wendy Lynch
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              Created:
              Updated: