With the released CMS schematron for RY 2016, CONF:1098-7508 currently cannot be met with @value since it appears that @xsi:type="IVL_TS" is required by the schematron, PSVA, and QualityNet. While the HL7 R3 QRDA specifications state data Type IVL_TS in Table 132, there is no mention of IVL_TS in the main body and specifically states that @value or low should be acceptable.

According to the specifications, @value should be used for a single-administration timestamp whereas low and high should be used for medication start and stop times.

As a workaround, all single administrations will now have to be sent with IVL_TS data type and a low timestamp going against the HL7 specifications just in order to satisfy the CMS schematron.