• Still uses UCUM annotations but capitalization is different. * {inr}

• Still uses UCUM annotations but capitalization is different. * 1 - The UCUM unity is technically dimensionless.

• {INRPOC}

• Still uses UCUM annotation. 
   
  We are not opposed to the removal of HQR Validation CMS_0086; however, we not confident that the removal will provide more benefit than confusion. CCDE and eCQM submission periods are significantly different for 2023. Leaving CMS_0086 would provide notification to submitters if they accidentally upload zipped documents containing both CCDE and eCQM files. 
   
  Section 6.1 and Table 18 have the same minor typo: "Laboraty Test, Performed" 
  Thank you for your feedback.
  1)      According to the UCUM specification, annotations are meaningless. The HQR receiving system will not reject files if other UCUM annotations were provided for an INR result than the recommended. UCUM annotations provided have no impact on measure calculations using INR results by the HQR receiving system.
  2)      Upon further discussion with the HQR receiving system team, CMS_0086 will be added back to the final version of the IG.
  3)      The noted typo in Section 6.1 and Table 18 will be corrected. 
   |

  Comment by Manish Parekhji [ 04/19/22 ]

  In the draft 2023, CMS QRDA CAT I guide, the following validation is being removed. 5.3.2 Additional HQR Validations 2023 CMS QRDA IG: Removed CMS_0085 2022 CMS QRDA IG: CMS_0085: CMS program name for hybrid measure/CCDE submissions must be HQR_IQR_VOL Questions: # Does that mean for Hybrid Measures QRDA CAT I file submissions the allowable Program Name is - HQR_IQR?

1. Are following values valid for hybrid measures QRDA CAT I files - HQR_PI_IQR or HQR_PI? Since Hybrid Measures are part of the Hospital IQR program and not Promoting Interoperability Program are any of these 2 values invalid?
2. If HQR_PI_IQR or HQR_PI are invalid for Hybrid Measures QRDA CAT I files, will QNet reject the Hybrid Measures files when they are submitted with one of these invalid values? Is there any validation defined for these?
3. Additionally, if HQR_IQR is a valid value for Program Name for both hybrid measures and eCQMs, does that mean a single QRDA CAT I file can contain data for both eCQMs and Hybrid Measures?
   We are trying to figure out if there is a requirement that Hybrid Measures and eCQMs be submitted in separate QRDA CAT I files. Since the reporting period is different for eCQMs (CY - Jan 1 - Dec 31, 2023) and Hybrid Measures (July 1, 2023 to June 30, 2024), it seems like it might be better to require that eCQM and Hybrid Measures data not be combined in the same QRDA CAT I file. The validation - CMS_0085 - that is proposed for removal from 2023, was helping ensure in 2022 that Hybrid Measures and eCQM data would be submitted in separate QRDA CAT I files (files with Program Name HQR_IQR_VOL would be for Hybrid Measures and the other program names - HQR_IQR, HQR_PI, HQR_PI_IQR - would be for eCQMs).

Any guidance on the above would be very much appreciated.
Thanks!
Thank you for your feedback.
1)      HQR_IQR is the correct program name to use for hybrid measures/CCDE submissions. We will add back CMS_0085 to valid CMS program name for hybrid measure/CCDE submissions must be HQR_IQR.  
2)      A single QRDA I file cannot contain data for both hybrid measures and eCQMs. Hybrid measures and eCQMs cannot be submitted in the same batches.
 |

1. If the same batch (zip) is allowed to include both eCQM and Hybrid Measures xml files, what will be the impact on the submission deadlines?
2. Example - eCQM submission deadline for Q3, 2022 (CY2022) data will be Feb 28, 2023. But Hybrid Measures data submission deadline for Q3, 2022 will be October 1, 2023. If some is uploading a zip file for Q3, 2022 in August of 2023 and the zip includes both eCQM and Hybrid Measures data for Q3, 2022, will the eCQM data be rejected because the submission deadline for eCQMs has passed?

It would be very helpful if specific requirements about the above are defined in the specifications.
Thanks!
Thank you for your feedback. Upon further discussion with the HQR receiving system team, CMS_0086 will be added back to the final version of the IG.  Hybrid measures and eCQMs cannot be submitted in the same batches.|

Any guidance on the above would be very much appreciated.
Thanks!
Thank you for your feedback.
1)      HQR_IQR is the program name to be used for hybrid measures/CCDE submissions. Upon further discussion with the HQR receiving system team, CMS_0086 will be added back to the final version of the IG.
2)      The unit for systolic blood pressure was a typo and will be corrected to mm[Hg].
3)      There would be no change in the Platelet count lab test value set. By referencing “Platelet”, we are consistent with the hybrid measure specification header elements: Supplemental Data Elements and Guidance.|

As per QRDA IG, the Result template (2.16.840.1.113883.10.20.24.3.87:2019-12-01) used in Laboratory Test Performed allows for effectiveTime attribute to come only as effectiveTime/@value(CONF-4444-30014), making effectiveTime a SHALL and effectiveTime/@value a SHALL.

Currently, there is no Schematron validation corresponding to CONF-4444-30014. Thereby allowing Result template(2.16.840.1.113883.10.20.24.3.87:2019-12-01) to come both as effectiveTime/@value or effectiveTime/@low and effectiveTime/@high. Can such an assert statement be added to the Schematron for 2023?

Questions:

1. For Hybrid measure we noticed that the program Name - HQR_IQR_VOL is removed , since it is not voluntary starting from 2023 Reporting. Could you please guide us with the right program name for Hybrid Measures. Or Is Hybrid going to take the same program names as eCQM's based on the submission program?
2. We noticed that conformance_0085 has been removed due the the removal of voluntary submission program name. Could you please give us more clarity on why CMS_0086 was removed. Since hybrid measures and eCQM's follow different reporting period and different submission timelines, Is it possible for us to submit these files in same batch?
3. In the newly introduced table 19, we saw that the unit for systolic Blood pressure for Hybrid HWR is mentioned as meq/L, mmol/L. We would like to understand if this is the correct unit for Systolic blood pressure. Also, in the same table we saw that one of the core clinical data elements is mentioned as ‘Platelet’ wherein as per the Hybrid HWM measure specifications, the value set is Platelet count lab test. Would there be any change in the value set corresponding to Platelet count lab test?

Any guidance on the above would be very much appreciated.

Thanks!

Regarding the proposed removal of CMS_0086

5.3.2 Additional HQR Validations
2023 CMS QRDA IG: Removed CMS_0086
2022 CMS QRDA IG: CMS_0086: Files containing hybrid measure/CCDE submissions and eCQM cannot be submitted within the same batch

We agree with Alex that retaining CMS_0086 would be helpful to ensure that zipped documents containing both Hybrid Measures(CCDE) And eCQM files are not combined in the same batch and if they are a notification will be provided. We recommend keeping this validation.

Questions

1. If the above validation is removed, and if a zip file is uploaded to QNet that contains some XML files with eCQM data and others with Hybrid Measures data, how will QNet address it?
   1. Will QNet import the eCQM data from or will they ignore it?
   2. Will QNet import the hybrid measure data or will they ignore it?
   3. What will QNet use to determine if the zip file is being uploaded for uploading Hybrid Measures data or eCQM data?
   4. Or is there an expectation that zip files can include both hybrid measures and eCQM data in the same batch for a given quarter?
2. If the same batch (zip) is allowed to include both eCQM and Hybrid Measures xml files, what will be the impact on the submission deadlines?
   1. Example - eCQM submission deadline for Q3, 2022 (CY2022) data will be Feb 28, 2023. But Hybrid Measures data submission deadline for Q3, 2022 will be October 1, 2023. If some is uploading a zip file for Q3, 2022 in August of 2023 and the zip includes both eCQM and Hybrid Measures data for Q3, 2022, will the eCQM data be rejected because the submission deadline for eCQMs has passed?

It would be very helpful if specific requirements about the above are defined in the specifications.

Thanks!

In the draft 2023, CMS QRDA CAT I guide, the following validation is being removed.

5.3.2 Additional HQR Validations
2023 CMS QRDA IG: Removed CMS_0085
2022 CMS QRDA IG: CMS_0085: CMS program name for hybrid measure/CCDE submissions must be HQR_IQR_VOL

Questions:

1. Does that mean for Hybrid Measures QRDA CAT I file submissions the allowable Program Name is - HQR_IQR?
2. Are following values valid for hybrid measures QRDA CAT I files - HQR_PI_IQR or HQR_PI? Since Hybrid Measures are part of the Hospital IQR program and not Promoting Interoperability Program are any of these 2 values invalid?
3. If HQR_PI_IQR or HQR_PI are invalid for Hybrid Measures QRDA CAT I files, will QNet reject the Hybrid Measures files when they are submitted with one of these invalid values? Is there any validation defined for these?
4. Additionally, if HQR_IQR is a valid value for Program Name for both hybrid measures and eCQMs, does that mean a single QRDA CAT I file can contain data for both eCQMs and Hybrid Measures?
   We are trying to figure out if there is a requirement that Hybrid Measures and eCQMs be submitted in separate QRDA CAT I files. Since the reporting period is different for eCQMs (CY - Jan 1 - Dec 31, 2023) and Hybrid Measures (July 1, 2023 to June 30, 2024), it seems like it might be better to require that eCQM and Hybrid Measures data not be combined in the same QRDA CAT I file. The validation - CMS_0085 - that is proposed for removal from 2023, was helping ensure in 2022 that Hybrid Measures and eCQM data would be submitted in separate QRDA CAT I files (files with Program Name HQR_IQR_VOL would be for Hybrid Measures and the other program names - HQR_IQR, HQR_PI, HQR_PI_IQR - would be for eCQMs).

Any guidance on the above would be very much appreciated.

Thanks!

Section 5.2.3.2 added information for representing unitless values with UCUM annotations in curly braces. So long as they represent the UCUM unity or dimensionless values, will any UCUM annotation be accepted for an INR result?

For example, will these following PQ.unit UCUM codes be accurately calculated?

• {Ratio}

  - Still uses UCUM annotations but capitalization is different.

• {inr}

  - Still uses UCUM annotations but capitalization is different.

• 1 - The UCUM unity is technically dimensionless.
• {INRPOC}

  - Still uses UCUM annotation. 

We are not opposed to the removal of HQR Validation CMS_0086; however, we not confident that the removal will provide more benefit than confusion. CCDE and eCQM submission periods are significantly different for 2023. Leaving CMS_0086 would provide notification to submitters if they accidentally upload zipped documents containing both CCDE and eCQM files. 

Section 6.1 and Table 18 have the same minor typo: "Laboraty Test, Performed"