Response to Question 1: The intent of the measure is that the medication is prescribed within 3 months of Occurrence A of Laboratory Test, Result: CD4+ Count. The "Medication, Order: Pneumocystis Jiroveci Pneumonia (PCP) Prophylaxis" <= 3 month(s) starts after end of "Occurrence A of Laboratory Test, Result: CD4+ Count" is the way that intent is represented in HQMF logic. Response to Question 2: To meet the intent of the measure, the medications should be ordered at the same time. Unfortunately, we are limited with how we can represent that in HQMF logic. Using a phrase like "concurrently" would mean the provider must enter the order for each medication at the same exact time down to the minute. The use of the "<1 day" in the logic was in recognition of the fact the providers might not enter each medication into the system at the same exact minute. The medications should be ordered on the same day, though. Elissa Chandler provided the following additional comments directly to Jeff McCartney via email on 11/5/2013 at 1:34 p.m. 1) : So then the medication just has to be prescribed within 3 months of Occurrence A of Laboratory Test, Result: CD4+ Count Or can be prescribed during the Occurrence A of Laboratory Test, Result: CD4+ Count. And does not have to be prescribed within 3 months starting the day 'AFTER' Occurrence A of Laboratory Test, Result: CD4+ Count, correct? RESPONSE: The medication can be prescribed at any point after the CD4 count result as long as it's no longer than three months after the lab test result. 2) New question regarding Initial Patient Population 1: In the initial Patient population Criteria the measure requires Occurrence A and B of HIV Visit during the measurement period. And I am aware from the definition provided for the measure logic the 'Occurrence A' and 'Occurrence B' is not define as chronological order such as A means 'first' and B means 'Second'. Hence, if we have 4 qualifying HIV encounters during the measurement, how are Occurrence A and B HIV Visits selected out of the 4 possible qualifying encounters. Example: There are 4 encounters for HIV Visits- which should be defined as Occurrence A and Occurrence B? • Encounter 1 : HIV Visit on 1/1/13 • Encounter 2 : HIV Visit on 2/1/13 • Encounter 3 : HIV Visit on 2/15/13 • Encounter 4 : HIV Visit on 3/1/13 RESPONSE: This comment is less about the measure and more about how occurrencing in eMeasure logic should work. Refer to the eCQM Logic Guidance document for further info on occurrencing. http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2014_eCQM_Measure_Logic_Guidance.pdf 3) New question regarding # Initial Patient population and Denominator Exception Laboratory Test: Similar to the question above in the initial Patient population Criteria the measure requires 'Occurrence A of Laboratory Test, Result: CD4+ Count (result < 200 per mm3)" < 9 month(s) ends after start of "Measurement Period'. And then in the denominator Exception we have a requirement for 'Occurrence B of Laboratory Test, Result: CD4+ Count (result >= 200 per mm3)" <= 3 month(s) ends after end of "Occurrence A of Laboratory Test, Result: CD4+ Count'. So again if we have 2 qualifying CD4+ Count (result < 200 per mm3) < 9 month(s) ends after start of Measurement Period... and 2 qualifying CD4+ Count (result >= 200 per mm3 within 3 months from both of the two test CD4+ Count (result < 200). Then Which would be considered the 'Occurrence A of Laboratory Test' and which would be considered as 'Occurrence B of Laboratory Test' as there two test that means each of occurrence A and B criterions requirement? So do we take the most recent or the first test? Please advise, thank you Example: There are four CD4+ Count Test with results, which should be defined as Occurrence A and Occurrence B? • Encounter 1 : CD4+ Count with result < 200 on 1/1/13 • Encounter 2 : CD4+ Count with result < 200 on 2/1/13 • Encounter 3 : CD4+ Count with result >= 200 on 3/1/13 • Encounter 4 : CD4+ Count with result >= 200 on 4/1/13 RESPONSE: Refer to the eCQM Logic Guidance document for further info on occurrencing. http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/2014_eCQM_Measure_Logic_Guidance.pdf