This issue spawned from CQM-3317, where the reporter was asking for more information regarding the intent of using Author dateTime vs Relevant Period for negation rationale.  When we were looking through the QDM to see if there was guidance supporting our rationale (negationRationale thought of as a single point in time), we could not find it. However, we did find on page 45 or QDM 5.3, in the Negation Rationale definition, this blurb (see attached negation definition pic).  

Floyd's recommendation:

Thanks for the context and the additional information from QDM documentation. So I think the following is true:

1. The text in the Negation Rationale definition you quoted was actually not accidental but perhaps less clear than it should have been. “Note: Some datatypes include both Relevant Time and Author dateTime attributes.  The purpose is to accommodate Author dateTime if the actual start and stop times are not available when evaluating for feasibility, and also to allow specification of a time for Negation Rationale.”  The issue is that Negation Rationale is an attribute in QDM and it doesn’t have its own timing attribute.  Hence, the intent of the statement should be interpreted to indicate that Author dateTime may be used by measure developers even when Relevant Period applies but is routinely not available, but for Negation Rationale is another reason for including Author dateTime.  I.e., Negation Rationale references some documentation why something that should have happened did not happen.  That documentation has no time period, it is a single point in time represented by author dateTime. With that said, actually finding a reason for non-occurrence of an activity is not a common activity in EHRs except, perhaps as a response to a recommendation by clinical decision support (either a response to an event-action-response-alert, part of a documentation template or a response to an item in an order set if so configured). Actual implementation in the eCQM world may be specific to creating an entry field solely to meet the needs of measure data collection and not included as available data for use by other clinicians. If that is true, then one must consider the potential for additional burden to clinicians.
2. The clearest way to assure Negation Rationale is restricted to author dateTime is to establish parallel QDM datatypes for every one that allows negation (e.g., Procedure, Not Performed as a separate datatype that has only 1 timing). We rejected that approach to avoid explosion of datatypes. Therefore, I believe that publication of Known Issues to clarify the langue in QDM 5.3 and 5.4 and specify that negation rationale only uses author dateTime.

As for the issue to which to assign the ticket, it is about reporting and QRDA should allow only author dateTime for negation rationale based on the intent of the QDM CMS “standard” data model. Hence it is a QRDA ticket issue.

Setting up a related issue in QDM Tracker to generate the known issue is also reasonable.

Bottom line, careful reading of the statement means we should reword it in the negation rationale description. But it does state the purpose of author dateTime is “to allow specification of a time for Negation Rationale.”  So the Known Issue should address clarification.

The Joint Commission recommends revising the definition for the negation rationale attribute to make it more clear that for this attribute, we will only use author dateTime.