For EH measures, the reporting requirements are specified in the CMS QRDA-I implementation guide for EH. This is downloadable from QualityNet website,
https://www.qualitynet.org/dcs/ContentServer?c=Page&pagename=QnetPublic%2FPage%2FQnetTier3&cid=1228772217179 “CMS Hospital Reporting (HR) Quality Reporting Document Architecture (QRDA) Category I Release 2 Supplementary Implementation Guide - 2014 data submission, PDF-527 KB (11/12/13)”. Per the CMS QRDA-I implementation guide for EH, nullFlavor is not allowed for race, ethnicity, and gender. For example, if a patient race is not recorded in an EHR because patient has declined to provide the information, QRDA-I report for this patient will be rejected. This requirement will stay as it is until the next release of the CMS QRDA-I implementation guide for EH will be published, which is likely in the July, 2014 time frame. (3/7/2014: an update to the CMS QRDA-I guide for EH, a draft Version 2.2 is available at
http://jira.oncprojectracking.org/browse/HQRIG-1 for public comments. NullFlavor is allowed in this draft.)
For EP measures, the reporting requirements are specified in the 2014 CMS QRDA-I implementation guide for EP programs, which is available at the CMS site
http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/ClinicalQualityMeasures.html. Per the CMS QRDA-I implementation guide for EP, nullFlavor is allowed for race, ethnicity, and gender (note, this differs from the current EH reporting requirements). For example, if a patient race is not recorded in an EHR because patient has declined to provide the information, a nullFlavor should be sent for /ClinicalDocument/recordTarget/patientRole/patient/raceCode.
If race isn't recorded (or any other supplemental data element):
QRDA-I: Send a null value (even if the value isn't recorded because patient refused). (Note: This applies to EP measures. EH measures have a different requirement as described above.)
QRDA-III: Not an issue, because you are only sending positive counts. In other words, if you don't know that the patient is Hispanic (or non-Hispanic), you don't count them as Hispanic (or non-Hispanic) (Note: This applies to EP measures. For 2014, aggregated reports for EH measures are done through attestation.) (3/7/2014: a clarification to this: if race is not recorded for a patient, the patient will not be counted (what the "positive counts" was referring to). If the total count for race for all patients is zero (all patients do not have race data in the EHR), zero as a total count still should be reported.)