Our team is currently updating QRDA Category I report generation to align with 2026 specifications. While CMS has published the following 2026 QRDA guidance documents:

• 2026 CMS QRDA I Implementation Guide for Hospital Quality Reporting (HQR) — published May 2025
• 2026 CMS QRDA III Implementation Guide for Eligible Clinicians — updated December 2025

There is no published 2026 CMS QRDA Category I Implementation Guide specifically scoped to Eligible Clinicians (ECs). This gap creates ambiguity for implementers who generate patient-level QRDA Category I documents within EC program contexts (e.g., for ONC CEHRT certification, payer-aligned quality programs, or pre-aggregation data capture prior to QRDA III submission).

Historically, QRDA Category I has been scoped to hospital reporting at the CMS program level. However, EHR systems certified under ONC CEHRT must produce QRDA Category I output for Eligible Clinician eCQMs as part of certification testing (e.g., via Cypress). This creates a practical need for EC-specific QRDA Category I conformance guidance that is currently unaddressed for the 2026 performance period.

Questions:

1. Is CMS planning to publish a 2026 QRDA Category I Implementation Guide specifically for Eligible Clinician programs and/or ONC CEHRT certification use cases? If so, what is the anticipated timeline?

2. In the absence of a 2026 EC-specific QRDA Category I IG, is it appropriate for implementers to apply the 2026 CMS QRDA I HQR IG (V9 template, Federal Administrative Sex value set) as the authoritative structural baseline for EC-context Cat I documents?

3. Are there any known deviations or EC-specific conformance requirements that should be applied on top of (or instead of) the HQR IG when generating QRDA Category I for Eligible Clinician eCQMs?

4. For ONC CEHRT certification testing via Cypress for the 2026 period, which QRDA Category I IG version and Schematron should be used to validate EC eCQM Category I documents?