In the CQL-based measures for CY 2019 reporting, negation is represented using datatypes such as Device, Not Applied or Medication, Not Discharged, etc. I’ve attached HQMF and ELM examples of this. Since this was also present in the draft version of the measures, we’ve updated our software to expect and accommodate these datatypes when performing measure calculation. 

However, in the CMS Implementation Guide for Quality Reporting Document Architecture Category I Hospital Quality Reporting Implementation Guide for 2019, it states that negation should be represented as follows:

QDM attribute: Negation Rationale is represented by setting negationInd="true" and stating the reason (rationale) in a contained Reason (V3) template. 

In the present HL7 standard for QRDA Cat 1 it is nowhere specified or mentioned to use the new negation datatypes. I also have attached a screen print from the sample QRDA xml. 

As a vendor, this presents a significant disparity between what the measure definition expects vs what the QRDA expects. This disparity has a substantial impact on our implementation of the CQL-based measures. 

Why does the QRDA not account for these new datatypes for negation? Can you please explain the disparity and provide a recommendation to vendors? 

Since this is a time-sensitive issue for us, prompt consideration is appreciated.