In the HL7 Implementation Guide for QRDA I Templates STU 5, it removes the sdtc:valueSet for multiple QDM Elements like Device Applied, Device Order, and Intervention Order just to name a few. my question is how will negation work. Per the eCQM Logic and Implementation Guidance V2, it states:

"In the May 2016 eCQM release, the QRDA Category I Release 3 and CMS QRDA Implementation Guide directed implementers instead to use null values to replace a specific code associated with a value set when describing activities that were negated or “not done.” Thus, providers are not required to specify that they did not perform a specific member from the value set; rather, the recommended approach is that they will indicate what they did not do on any of the items in the value set. This approach is intended for use with all datatypes that use negation to describe activities “not done.” It does not change the expression of negation in the HQMF; however, it does require using an HL7 nullFlavor code instead of a specific code from the value set associated with these activities in the QRDA Category I file.
The intent of the null flavor in this context is to specify that ALL the activities in the value set were intentionally not done, not that a single activity was not done or that it is not known why that activity was not completed. It is not appropriate for users to certify that an activity was not done using negation unless the provider intentionally did not order or perform the activity in question and documented a justification why that was the case."

"In referencing value sets used to negate activities, developers had previously used ingredient-level value sets to group medications for negation because this provided improved usability to providers. Now that the updated approach allows negation of the entire value set, the same detailed value sets used for Medication, Order or Medication, Administered in the measure logic can be used throughout and the logic can be implemented in a more workflow-friendly fashion. Ingredient-level value sets have been retired for negation purposes, but are still used for allergies. This approach also should streamline additional types of negations, such as groups of procedures."

It gives this example of how to null flavor the code with "NA" and negate the value set itself. If the sdtc:valueSet is removed from Device Order, how are we able to specify which value set is being null flavored? There doesn't seem to be a place for a sdtc:valueSet in Reason either.