In the final 2023 QRDA CAT I IG published in May 2022, CMS has removed the validation (CMS_0084) for Hybrid Measures for 2023 (July 1, 2023 to June 30, 2024) reporting -

From the 2022 QRDA CAT I Implementation Guide

From Page 64 of the 2023 QRDA CAT I Implementation Guide (https://ecqi.healthit.gov/sites/default/files/QRDA-HQR-2023-CMS-IG-v1.508.pdf )

For the 2022 reporting period (in the 2022 QRDA CAT I IG) for hybrid measures submission CMS requires either a HICN or MBI to be submitted. If one of them is not provided, CMS will reject the QRDA CAT I file.

By removing this validation for 2023, a Hybrid Measures QRDA CAT I file can be submitted without either the HICN or the MBI for 2023 reporting.

Question -

1. Does CMS truly intend to accept Hybrid Measures files without both MBI and HICN? How will CMS link the patient to the Medicare claims without wither HICN or MBI?
2. In the Draft 2023 QRDA CAT I spec that was provided for submission of feedback (https://oncprojectracking.healthit.gov/support/browse/QRDA-1060) there was no mention that this validation (CMS_0084) is proposed to be removed. But in the final 2023 QRDA CAT I IG, it got removed. That is why I'm wondering if CMS really intends to remove this validation or is it an error

It seems to me that CMS may not be able to link a patient from the Hybrid Measures file to the Medicare claims if both HICN and MBI are missing in the file.

Can someone review and confirm for us that this validation is truly being removed?

And will CMS provide any sort of error message if both are missing in the file?

Thanks in advance for your review and response.