As referenced in ONC JIRA QRDA-124, the proposed solution indicates that when payer information is not available for a patient, the template may use nullFlavor="NI". As we also know, this is a standard practice followed across other templates too when information is not available. 
 
However, while validating this scenario using Cypress Conformity (version 7.5.0, program: HQR_IQR and other programs), we encountered the following error:

“The Patient Data Section QDM (V6) - CMS shall contain at least one Patient Characteristic Payer template and at least one entry template that is other than the Patient Characteristic Payer template.”

For reference, a sample patient XML is attached - 8_Oscar_Burns.zip. 8_Oscar_Burns.zip
 
Additionally, the HQR Implementation Guide
(CMS Implementation Guide for Quality Reporting Document Architecture Category I – Hospital Quality Reporting, 2026 Version 1.0, dated 05/20/2025) specifies that payer is a “shall” requirement.
 
At the same time, the guide references the base specification HL7 QRDA I STU 5.3 (with errata), where payer appears to be optional (similar to the ambulatory setting).
 
 
Given this context, our question is:
While payer is defined as a “shall” condition and we are able to include the payer template, is it acceptable to populate it with
<value xsi:type="CD" nullFlavor="NI"/> in scenarios where payer information is genuinely unavailable in real-world data?
 
I would appreciate your guidance here.