QRDA III Conversion Software Question

[Pawan Jindal(MyMipsScore.com)]

Hello,

We used the QRDA III conversion software made available last week. It seems that the software only works with the latest QRDA III specs and also with a specific version of the CQMs mentioned in the measures.json file. We are working with a number of EHRs that were certified for a previous version of the QRDA III. The CYPRESS tool used to validate QRDA III for certification does not work with this latest specifications. The changes/issues are more than just the addition of ACI and IA category as separate components . As an example, the certified version still requires reporting parameters as a separate component but the new format requires them as part of each category component separately.  The measures.json file only provides stratum Ids for measures of a particular version. Even if the schema is updated to the latest one, all the multi-performance measures conversion fail if the EHR was certified with a previous version of eCQM?  We would really appreciate if you could clarify the following questions for us:

• Would there be any separate certification/requirements for vendors who would like to submit data in the new QRDA III format? It is important to mention that this latest version of QRDA III does NOT pass the testing even with the latest version of Cypress. So there is no option for vendors to be certified with the above version.
• If the answer to above is no,
• Can the EHRs update their QRDA III export process to support the above format? We have tried to get clarification from the testing bodies but didn't get a clear answer.
• The conversion software automatically submits all measures "EndToEndReport" to true. Many EHRs support measures (that are common for both EHR and registry) that they were not certified for but users can report the result using a registry. Can a provider using such an EHR report this measure through the new QRDA III format? It will be the same process used to report those results to Registry. Will it still allow for EndToEnd bonus?

Thanks,

Pawan

[Pawan Jindal(MyMipsScore.com)]

Any thoughts on this? 

We are working with multiple EHRs that are looking for clarification on this. As has already been discussed in another post https://groups.google.com/forum/#!searchin/qpp-apis/ehr$20submission%7Csort:date/qpp-apis/6Ac3AyW36nU/pYKUkiM4BwAJ , we were also involved with multiple EHRs to get them ready for the API, only to find out at the end that we wouldn't be able to use it. It would really be helpful if someone could clarify the requirements of creating/using the QRDA III for MIPS submissions for EHRs/Third Party vendors before we put too much effort to get ready for this. 

[Mari Miyachi]

Hi Pawan,

I believe this is a policy question - please reach out to q...@cms.hhs.gov.

[Jonathan Sullivan]

Hi Pawan,

Q1: Would there be any separate certification/requirements for vendors who would like to submit data in the new QRDA III format? It is important to mention that this latest version of QRDA III does NOT pass the testing even with the latest version of Cypress. So there is no option for vendors to be certified with the above version.

A1: Only the eCQM specifications for the 2017 performance period are allowed. Each year eCQMs go through an annual update. The correct version of eCQMs for a given performance period has to be used. The Cypress 3.2.0 that was released 7/27/2017 supports the HL7 QRDA III R2.1 and the eCQMs for the 2017 performance period (see the release notes: https://www.healthit.gov/cypress/release.html). The HL7 QRDA III R2.1 is what the CMS 2017 QRDA III IG is based on. The latest release of Cypress is 3.2.2. You should be able to install the latest Cypress and use the 2016 Bundle for the 2017 performance period. The Cypress Validator also supports validation of the latest QRDA III spec and the 2016 Bundle.

Q2: If the answer to above is no, can the EHRs update their QRDA III export process to support the above format? We have tried to get clarification from the testing bodies but didn't get a clear answer. The conversion software automatically submits all measures "EndToEndReport" to true. Many EHRs support measures (that are common for both EHR and registry) that they were not certified for but users can report the result using a registry. Can a provider using such an EHR report this measure through the new QRDA III format? It will be the same process used to report those results to Registry. Will it still allow for EndToEnd bonus?

A2: QRDA by nature is defined as End to End, as it requires programming of the eHR to output the measure results. The End to End bonus is only allowed for measures that are system generated and require no manual interaction with the data. If a user submits a Registry measure that also has an eHR spec and puts EndToEnd: True, it will be compared to the eHR benchmark and be awarded 1 point bonus. If there is no aligning eHR spec, it will be compared to the Registry benchmark and be awarded 1 point bonus. QRDA III as of now is only used for submitting eCQMs only. For those measures that do not have eCQM specifications, they cannot be submitted using QRDA III.

[Pawan Jindal(MyMipsScore.com)]

Hi Jonathan, 

Thank you for the detailed response. We have been using the 2016 bundle for 2017 with the 3.2.1 cypress version for all our testing. We were finally able to identify all the changes required to validate the QRDA III for both Cypress and QPP. We are waiting for a response from ONC to confirm that an EHR can make these updates without having to go through re-certification.  

Thanks again,

best,

Pawan