This issue is created in response to CYPRESS-716 where the current implementation of value set filter was described as acting not only on the template level but also on the attribute level. With import functionality essentially mandatory in the pre-released 2017 IPPS Rule, certification to Cypress 3.0.0 as currently implemented will run into a major issue as we previously reported with QRDA-184. Hospital organizations will be at high risk for incorrect measure status determination or may even be missing measure statuses completely.

If we update the scenario as described in QRDA-184 within the import framework, Patient A is seen at a hospital and has a principal diagosis of VTE. If we consider just hospital measures VTE-5 and VTE-6, the patient will qualify for the IPP for VTE-5 and will receive quality of care as measured by VTE-5. The patient will not qualify for the IPP for VTE-6 and potentially not receive quality of care as measured by VTE-6.

1 month later and in the same reporting period, the hospital has switched EHRs and patient A comes back with secondary (non-principal) VTE. For this second encounter, the patient will qualify for the IPP for VTE-5 and VTE-6 and will receive quality of care as measured by both VTE-5 and VTE-6.

As Cypress 3.0.0 is currently implemented, priorityCode will not and should not be included in Patient A Encounter 1 for the VTE diagnosis. We believe this creates a dangerous scenario when importing QRDA I and creating a unified QRDA document.

When the hospital organization wishes to create a unified QRDA I document for VTE-5 and VTE-6, there are two equally poor choices. If data from Encounter 1 and Encounter 2 are merged, reporting organizations who determine measure statuses from QRDA I will calculate that the patient was in the IPP for VTE-5 and VTE-6 for both Encounters 1 and 2. This is not an accurate reflection of the patient's quality of care. The patient had principal VTE in Encounter 1, but the current implementation of Cypress filtering requires that we leave the priorityCode off.

The other choice would be to not import Encounter 1 since we are choosing to generate documents for both VTE-5 and VTE-6 and the output document for Encounter 1 will only have VTE-5 listed in the measure header section; however, now organizations would not get credit for the quality of care given in Encounter 1.

We strongly urge Cypress, CMS, and any other receiving organization of QRDA I to strongly consider allowing priorityCode for Principal and Primary value sets to be sent for all eCQMs. This should not be considered extraneous data, and as shown, is critical for accurate implementation of QRDA I import.