Hello,

I am requesting clarification regarding the expected behavior for CMS129 (Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low-Risk Prostate Cancer Patients) when generating a QRDA Category I export.

Scenario

In our EHR system, a “group” is configured for QRDA I exports.
During the export process, we validate whether the provider associated with a patient encounter belongs to that group.

We encountered the following situations:

1. Case 1:

• • The provider referenced in the patient record is not part of the configured group,

• • But the provider does exist in our master provider table / provider lookup with valid identifiers (NPI, organization, etc.).

• • In this situation, the QRDA I export can be fully populated with all required elements.

1. Case 2:

• • The provider referenced in the patient record is not part of the group,

• • And does not exist in the provider lookup or provider table.

• • In this case, the required organization/provider elements cannot be populated, which results in a QRDA export failure.

Reason for the Question

Based on the CMS129 eCQM logic on eCQI (diagnosis-driven IPP qualification independent of provider identity), a patient may qualify for CMS129 without direct attribution to a specific provider in the group.

The QRDA I Implementation Guide and schematron validations require:

• Valid provider identifiers when reported,

• Valid organization information,

• Structural and template compliance.

However, we did not find explicit guidance on whether a QRDA I file is required to reject a patient solely because the provider is not part of the configured group—especially when the provider is otherwise valid and present in the provider database.

Request

Could you please confirm the correct, CMS-approved handling for Case 1?

Specifically:

Is it acceptable for QRDA I submission of CMS129 to proceed when the provider is not part of the submitting group, as long as the provider exists in the provider lookup/master table and all required QRDA elements (NPI, organization ID, etc.) can be populated?

Additionally:

Is there any CMS or eCQI guidance stating that provider “group membership” must be validated by the vendor before including a patient in the QRDA I export for CMS129 or other eCQMs?

Our goal is to ensure our implementation is fully compliant with QRDA requirements and CMS expectations, and to avoid blocking exports for valid CMS129-qualifying patients based solely on internal group configurations.

Any documentation references or official clarification would be greatly appreciated.

Thank you for your support.

Best regards,
Abhinav Giri
Greenway Health
Associate Product Manager