Cypress currently expects a mix of the HL7 QRDA R3.0 and R3.1 standards when testing for the 2016 RY. Specifically, the Device, Order template negation expects a negationInd at the Device Order Act level and several other characteristics consistent with the HL7 QRDA R3.1 standard. Furthermore, Device, Order template as currently implemented is missing many required elements such as supply and templateID. Device, Order template as currently implemented meets neither requirements from HL7 QRDA R3.0 or HL7 QRDA R3.1 standards. All other templates conform to the HL7 QRDA R3.0 standard.

The HL7 QRDA R3.0 standard has been adopted by CMS as the standard that should be considered when certifying for the Reporting Year 2016 measure bundle. In that standard, the specifications for the Device, Order negation causes a validation issue against CDA. This was raised with the HL7 CQI workgroup and documented in HL7 DSTU Comment 696. The workgroup decided to amend the wording published in the HL7 QRDA R3.1 standard, but an Errata to HL7 QRDA R3 standard has not been published.

Until that errata is published, Cypress should expect the R3.0 standard to be used for all templates, and should not produce an error for Device, Order negations when data is intentionally omitted so not to violate CDA. We request that Cypress is updated to no longer produce this error, or that ATLs would be instructed to ignore this error during certification.