The "CMS Implementation Guide for Quality Reporting Document Architecture Category I and Category III
Eligible Professional Programs and Hospital Quality Reporting (HQR)
Supplementary Implementation Guide for 2016" (often referred to as the 2016 CMS QRDA Combined SIG) has this constraint in it:

PQRS: If the payer is Medicare, Medicare HIC Number is required for PQRS (when the CMS Program Name is either "PQRS_MU_INDIVIDUAL" or "PQRS_MU_GROUP"). Medicare HIC Number is not allowed for non-Medicare patients.
HQR: Patient Identification Number is required for HQR. Medicare HIC Number is not required for HQR but should be submitted if the payer is Medicare and the patient has an HIC number assigned.
i. [HQR,PQRS] This patientRole SHOULD contain zero or one [0..1] id (CONF:1140-16857) such that it
1. SHALL contain exactly one [1..1] @root="2.16.840.1.113883.4.572" Medicare HIC number (CONF:1140-16858).

If the submitter does not provide a HIC number in the submission, for any reason, two warning messages are displayed. They are:

• [HQR,PQRS] This patientRole SHOULD contain zero or one [0..1] id (CONF:1140-16857) such that it SHALL contain exactly one [1..1] @root="2.16.840.1.113883.4.572" Medicare HIC number (CONF:1140-16858).
• This patientRole SHOULD contain zero or one [0..1] id (CONF:1140-16857) such that it SHALL contain exactly one [1..1] @root="2.16.840.1.113883.4.572" Medicare HIC number (CONF:1140-16858).

One is generated by the Schematron rules supporting the Base HL7 IG and the other is generated by the Schematron rules supporting the 2016 CMS QRDA Combined SIG.

There are several problems with this. They are:

• A CONF number should be associated with one, and only one, warning/error message. If the message is changed, in any way, then it need to be assigned a CMS_xxx error number.
• The assertion that generates the "[HQR,PQRS]" version of the warning message is exactly the same as the assertion supporting the Base HL7 IG. This means it is completely redundant and there is no need for the 2016 CMS QRDA Combined SIG version of the assertion.
• Finally, if this were to be implemented in the Schematron rules supporting the 2016 CMS QRDA Combined SIG, then it both should have a new CMS_xxx CONF number assigned to it and there should have been two versions of the assertion, one supporting (and displaying) the HQR note and one supporting (and displaying) the PQRS note.

It turns out that PQRS has already written an assertion that properly supports the PQRS specific note. If a HIC number is provided for a non-Medicare submission, or if a HIC number is not provided for a Medicare submission then the following error message is displayed:

For PQRS the HIC number, in a valid format, is required for Medicare patients. The HIC number is not allowed for non-Medicare patients (PQRS_10716).

The solution to this problem is to remove the ESAC assertion for CONF:16857 in the Schematron rules supporting the 2016 CMS QRDA Combined SIG.