Cypress version 7.0.5 is generating the following error when the vendor uploaded files do not include the telephone and email address information for test cases from Cypress that do have this information.

Since the CMS IG published on 03/23/2023 relaxed the requirement for the telecom elements for telephone and email from SHALL to SHOULD, we were expecting that QRDA files without these elements for Phone and Email would not be rejected. The QRDA file does include a <telecom> elemnt with nullFlavor in it.

But Cypress 7.0.5 is currently rejecting these files. 

We validated these files against the schematron provided by CMS and it does not generate these 2 ERRORS. The QRDA file the system exports does include a <telecom> element with nullFlavor in it which meets the requirement to have the one <telecom> element in which nullFalvor is allowed. 

Some systems may be storing the minimal PHI required to calculate and submit eCQM data to CMS. With Cypress generating ERRORs for QRDA files that do not include the email and phone, systems will be required to store these PHI elements that are not required by CMS. 

Expected

Since the CMS IG for 2023 is not requiring the telephone and email <telecom> elements, and since the associated schematron is not validating them as ERRORS, we believe the validation for these should generate WARNINGS and not ERRORS. This would help meet the CMS requirement and not force systems to store PHI elements that are not required.