Attached pdf has the description and question, which is also provided below. 

CY2025 CMS QRDA CAT I IG has validation – CMS_0063. As per this if a QRDA CAT I file is uploaded to CMS for the HQR_IQR program (so basically inpatient eCQMs), if it does not include an encounter with a discharge date in the reporting period, the QRDA CAT I file will be rejected.

We think this validation would be problematic for the CMS1074 - Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults (Facility IQR) – eCQM.

This eCQM has the following definition for Initial Population. As per this an encounter is included in the population, if either admit or discharge date is in the measurement period.

Let’s look at this scenario for an inpatient encounter –

Start (Admit) date – Dec 28, 2025

End (Discharge) date – Jan 2, 2026

Diagnostic CT Scan Performed for LOINC code (96914-7 - CT dose and image quality category) performed starts on Dec 29, 2025 8 AM and ends on Dec 29, 2025 9 AM.

In this example, the encounter meets all the requirements for the population criteria i.e. –

• It overlaps (because start date is in Q4, 2025) the measurement period of CY2025
• CT Scan starts during the inpatient encounter
• CT Scan ends during the measurement period .

Since this encounter would be in the population for this eCQM, we would create a QRDA CAT I file for this encounter and submit it to CMS.

However, our understanding is that CMS would reject this file using validation CMS_0063 because the discharge date is not in the measurement period (2025) or the reporting period (Q4, 2025) –

“If the CMS program name is other than HQR_OQR, the system SHALL reject QRDA I files if there are no Encounter Performed Discharge Dates within the reporting period found in the QRDA (CONF: CMS_0063).”

Could you help us understand how to get around this issue?

Is CMS planning to update the eCQM so that the “overlaps measurement period” clause used in the qualifying encounters will be changed to “during measurement period”, which would resolve this issue?