When submitting documents to Cypress for HQR programs for the 2017 Reporting Year, we receive the following CMS HQR_IQR Combined IG error:

A Coordinated Universal Time (UTC time) offset should not be used anywhere in a QRDA Category I file or, if a UTC time offset is needed anywhere, then it must be specified everywhere a time field is provided (CONF: CMS_0121).

We are sending UTC offsets everywhere in the document except for the reportingParameters/effectiveTime and the birthTime. We are getting the conformance error for the birthTime element in all test documents we submit.

The CMS HQR_IQR Combined IG specifies that the reportingParameters/effectiveTime element is an exception to the UTC rule since it is specific to the day. birthTime should also be an exception, since at other locations in the IG, birthTime is specifies to be precise to the day (unless a newborn's time of birth is needed for a measure. This is stated as the following:

This patient SHALL contain exactly one [1..1] birthTime
(CONF:1198-5298).
a. SHALL be precise to day (CONF:1198-5300_C01).
For cases where information about newborn's time of birth needs
to be captured.
b. MAY be precise to the minute (CONF:1198-32418).

Since a UTC offset isn't well defined for a date, the conformance statement CONF: CMS_0121 should only be applied to the birthTime element in the rare cases where this element contains a time specific to the minute. birthTimes specific to the day should not require UTC offsets. The 2 conformance statements in the IG seem to contradict each other, and make it impossible to successfully submit files to HQR programs for the 2017 Reporting Year.

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