Cypress 6.2.2 adds strict enforcement of author templateIds; however, it provides Author Participation sections which have insufficient information. In Author Participation, assignedAuthor / id, the id should be equal to a pointer to an author in the header or all author components required in US Realm Header must be included as well (CONF:1098-32628).

When importing documents for CMS-506 in Cypress 6.2.2, the assignedAuthor / id is nullflavor="NA", which in our opinion, is nonconformant and should not be reexported within the Author Participation section. When exporting the files, we send the author / time within an Author (V2) section since it explicitly allows for a nullFlavor in assignedAuthor / id (CONF:4444-30006).

If there needs to be strict enforcement of author templateIds, we'd request that the provided documents contain all necessary information in the Author Participation sections in order to be conformant QRDA 5.2 documents. If there is an avenue to provide feedback to CMS as well, it is also important to note that any strict enforcement of author templateIds in submission systems means that not having a provider ID will result in not meeting the QDM Author Time element.

I've included two sets of files from our investigation. The Original Export file is the set of Cypress documents for CMS-506 directly exported from our system. This set of files fails c1 validation. The ManuallyAdd119 file manually adds The Author Participation (***.119) template for all discharge medications.  While we believe the nullflavor ID is nonconformant, it does pass c1 validation.