We are currently on Cypress 3.1. We see that the c4 Filter test requires the taxonomy code of the provider from the imported file to be passed through to the exported file.

Based on the guidance in the 45 CFR Part 170: 2015 Edition Health Information Technology (Health IT) Certification Criteria, 2015 Edition Base Electronic Health Record (EHR) Definition, and ONC Health IT Certification Program Modifications; Final Rule, we believe this test is outside of rule guidance.

The rule states: We thank commenters for the feedback. We agree that the Healthcare Provider Taxonomy Code Set (the “Code Set”) is the best available standard for classifying provider type at this point in time, and have therefore adopted the CMS Crosswalk: Medicare Provider/Supplier to Healthcare Provider Taxonomy, April 2, 2015 as the standard for provider type for this criterion (to the version updated April 2, 2015 as a minimum version for certification). This crosswalk maps the Medicare Provider/Supplier type to the relevant healthcare provider taxonomy codes. It is our understanding that when a provider registers for an NPI number, they are required to select at least one provider type code from the Code Set, but may select more than one code. However, the provider is required to select one code as the primary code. It is also our understanding that the NPI record for a given provider contains all codes a provider selected, and so we would expect that CQM results could be filtered by any one of the provider’s selected codes (e.g., primary, secondary, tertiary, etc.). In order to ensure the NPI record is up-to-date, we would recommend that health care providers update and/or verify their registration annually in the CMS National Plan and Provider Enumeration System (NPPES) to reflect the most accurate codes for the type of care the provider is currently providing. There are three methods by which an individual can access the NPI files: 1) through a downloadable file, 2) through a display/query on the NPPES website, and 3) through an interface to the NPPES API. While health systems may keep their own internal records of NPI information for the providers practicing in their system, we recommend that any of the three above methods provides the most up-to-date information and would encourage systems to verify and use this information for their internal records.

Based on the last, bolded section, we have implemented provider type checks based on the data available in the NPI database. Because the providers in the Cypress deck do not have NPIs included in the database, our implementation does not allow the taxonomy code to pass through.

We believe that based on the guidance in the rule, we should be reporting taxonomy code based on current NPI database data, rather than consuming a taxonomy code from an imported file and passing it through without verification and validation against the NPI database.

Please advise.