CMS347 fails during submission validation

[Gnana Krishnan]

"CMS347 - Statin Therapy for the Prevention and Treatment of Cardiovascular Disease" has 3 sub-measures / population criteria. However, this is not recognized and the QPP forms a JSON like this with just one set instead of three and this has got the NUMER and DENOM mixed up.

{

      "measureId" : "438",

      "value" : {

        "isEndToEndReported" : true,

        "performanceMet" : 0,

        "eligiblePopulationExclusion" : 0,

        "eligiblePopulationException" : 13,

        "performanceNotMet" : 128,

        "eligiblePopulation" : 103

      }

    }

and when we validate this for submission we get the following error:

{"errors":[{"sourceIdentifier":null,"type":"ValidationError","message":"invalid submission object","details":[{"errorCode":null,"message":"SV - field 'value' in Submission.measurementSets[0].measurements[24] is invalid: {\"isEndToEndReported\":true,\"performanceMet\":0,\"eligiblePopulationExclusion\":0,\"eligiblePopulationException\":13,\"performanceNotMet\":128,\"eligiblePopulation\":103} is invalid for measureId 438","value":null,"type":null,"location":{"location":null,"path":"/*[local-name() = 'ClinicalDocument' and namespace-uri() = 'urn:hl7-org:v3']","line":null,"column":null}},{"errorCode":null,"message":"SV - fields 'performanceNotMet, eligiblePopulationException, eligiblePopulationExclusion, eligiblePopulation' in Submission.measurementSets[0].measurements[24] are invalid: The sum of performanceMet, performanceNotMet, eligiblePopulationException and eligiblePopulationExclusion must not exceed eligiblePopulation","value":null,"type":null,"location":{"location":null,"path":"/*[local-name() = 'ClinicalDocument' and namespace-uri() = 'urn:hl7-org:v3']","line":null,"column":null}}]}]}

Could you please see if this is an issue with the QPP conversion tool?

[Sailesh Dixit]

In addition to Gnana's question, this measure is certified for the QRDA 3 format using the 3 sub-measure criteria as well. Is it expected that the QRDA III file is submitted as 3 sub-measures, and JSON is submitted as a single performance measure?? 

[saq...@flexion.us]

Hi Sailesh,

In regards to your question this is what I understood from what we were told. Only one performance rate should be reported for CMS347 - the weighted average of the three denominators (the sum of all three numerators over the sum of denominators).

Sam

[saq...@flexion.us]

Hi Gnana,

We were having issues similar to this one with two other measures. Please try your submission again as we deployed a fix yesterday. If you are still having problems, if you could submit your file here with all PII (Personal Identifiable Information) removed, we can test for any issues with the converter.

Thank you,

Sam

[Satej Prabhu]

Hi Sam and Gnana,

Did you find any resolution of this issue? I am facing same issue. Attached is my de-identified QRDA III xml and error from conversion tool.

https://qpp.cms.gov/developers/conversion-tool-sandbox

Error JSON:

{"isEndToEndReported":true,

"performanceMet":1,

"eligiblePopulationExclusion":0,

"eligiblePopulationException":0,

"performanceNotMet":55,

"eligiblePopulation":2}

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  Regards Satej

[Satej Prabhu]

By trying different combinations of counts, I trust converter is only picking up counts from 3rd stratum and root cause of issue is calculation of performance not met. The potential fix is to create an QRDA III file with only third stratum, this file passes both Cypress and QPP conversion.

Let me know what you think.

--

  Regards Satej

[saq...@flexion.us]

Hi Satej,

I am looking into your file currently now and will let you know what I find.

Sam

[Gnana Krishnan]

Hi Sam,

I am adding my QRDA Cat III file as well (redacted). It will be great, if you could please run this through and let me know as well.

Satej,

As of Friday, I was still facing the same issue.

Thanks

Gnana

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[Gnana Krishnan]

Apologies. I missed the attachment. Here it is.

[Satej Prabhu]

Thank you for the update. Awaiting for resolution.

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[basha shaik]

Hi All

We are also getting the same problem with the measure CMS68 using web version(attached files) and same files when i pass through QPP desktop version, it got converted successfully, Please suggest what's going on with Web version?

Regards

Feroz 

[saq...@flexion.us]

Hi Satej,

It appears you have the same issues with CMS347v1 as others. Only one performance rate should be reported for CMS347 - the weighted average of the three denominators (the sum of all three numerators over the sum of denominators). Please change the xml you are submitting to only include one stratum for CMS347v1. 

Thanks,

Sam

[Satej Prabhu]

Thank you for the response for Sam, 

I have three stratum which has performance rate followed by IPP, Denominator, Exclusion, Exception and numerator count for each of them.

When I removed performance rate 2 and 3 data, keeping the population records in there , it failed with same error. See attached file PerformanceRate1.xml

When I removed all the population data ( IPP, Denominator, Exclusion, Exception and numerator) for stratum 2 and 3. The file worked fine.  See attached file PerformanceRate1_AvgPopulations.xml. I believe this is the solution.

I have couple of questions here

1. Which stratum IDs should be included. Is it okay to have first stratum? Screenshot from 2018_CMS_QRDA_III_Eligible_Clinicians_and_EP_IG_v2_508.pdf

2. Performance rate => (Num1 + Num2 + Num3) / (Denom 1 + Denom 2 + Denom 3). This is what you recommend. 

3. How do we calculate each population for reporting

     a. Should it be the populations of Stratrum 1 only

     b. Or it should be average of all three populations For e.g  IPP = (IPP1 + IPP2 + IPP3) / 3 , (Denom = Denom 1+ Denom2+ Denom3)/3 .. and so on. How do I round this data?

Finally do we have a reference guide from CMS/QPP which elaborates more on this. This help us in case of internal/external audits.

Regards

Satej 

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  Regards Satej

[John Mahoney]

Sam,

Can you please provide the guidance you have that indicates CMS347 which has 3 subpopulations should be reported with a singular rate?

We are having the same issue with submissions of CMS347 to the QPP.

Thanks for your help.

-John

[saq...@flexion.us]

Hi Satej,

Removing performance rate 2 and 3 and all their subpopulation data makes the submission have a single performance rate. This works because that is what QPP is expecting. The problem is that it may not represent the correct data unless you calculate the weighted average. For the weighted average, I have asked for documentation on how the average is calculated. Once I find out more information, I will pass it along to you.

Thanks,

Sam

[Sailesh Dixit]

Thank you sam...

On Wednesday, January 16, 2019 at 11:02:51 AM UTC-5, saq...@flexion.us wrote:

Hi Sailesh,

In regards to your question this is what I understood from what we were told. Only one performance rate should be reported for CMS347 - the weighted average of the three denominators (the sum of all three numerators over the sum of denominators).

Sam

On Monday, January 14, 2019 at 12:31:35 PM UTC-6, Sailesh Dixit wrote:

In addition to Gnana's question, this measure is certifieH

[Sailesh Dixit]

Hi Sam, 

Any updates on the formula that we should be using as a guide to change the performance rate to one calculation ?? This guidance would really help us in making sure that we are submitting correct numbers on the file. 

Best regards, 

Sailesh

[saq...@flexion.us]

Hi Sailesh,

The issue lies more with the Conversion Tool. There is be a fix coming schedule to come on Monday for this issue. We found that you still need to submit the QRDA-III document with 3 strata but once it is converted into QPP, it needs to be converted into one strata. I will be sure to let you know when we have a fix out.

[Satej Prabhu]

Hi Sam,

Is there any update on this? Our customers waiting on us.

Satej

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[saq...@flexion.us]

Hi Satej,

We have a fix for this issue but could not deploy it yet, due to needing verification and documentation. I have received the verification yesterday estimate the fix will be deployed at the latest Monday(2/4). I will comment in this thread once the fix has been deployed.

Sam

[Debbie Mobley]

We're experiencing this issue as well for 2 of our customers attempting to submit this measure.  We'll try again once you post that the fix has been deployed.

Debbie Mobley

[saq...@flexion.us]

Hi Sailesh,

I couldn't find you original post in here but as for submitting CMS347v1, you will submit it as 3 separate strata as the QRDA-III implementation guide suggests.

Sam

On Friday, January 25, 2019 at 2:03:10 PM UTC-6, Sailesh Dixit wrote:

[QCDR Developer]

This thread appears to have a lot of conflicting information coming from the moderators. I believe we are still waiting on detailed information on how to calculate the single performance rate as referenced earlier in this thread. I am not confused by the reference to 3 strata in the most recent email. It is imperative that clear guidance be given on this matter as soon as possible, as we are all developing systems to support customers that are facing an ever-dwindling submission window. 

[saq...@flexion.us]

Hi all,

The a new fix has been deployed to production for the Conversion Tool as of today. The submission expects 3 strata for CMS347v1 and now converts it into QPP properly. Please try your submissions again and let us know if you have any problems.

Thanks,

Sam

[Debbie Mobley]

Thanks, the upload completed successfully for CMS347.

[Sailesh Dixit]

Hey Sam, 

We are still waiting on the calculation guidance for QPP JSON file format submission. Is there a formula that we can refer to for this calculation??  Please provide guidance on this so that we are able to update our system to aggregate the numbers for submission purposes. 

Best regards, 

Sailesh

[Sarah White]

Hi Sailesh,

As Sam mentioned in an earlier reply, we made a change to the conversion tool, so you should submit it with the 3 rates to the conversion endpoint and it will generate one performance rate for submission in JSON.

Sarah White

Business Analyst

Nava

To view this discussion on the web visit https://groups.google.com/d/msgid/qpp-apis/3c1f254b-c210-453a-90ad-65cf3aa9df35%40googlegroups.com.

[Sailesh Dixit]

Hi Sarah, 

Thank you for quick reply. However, from what i understood the fix was applied to consume QRDA 3 files and not QPP JSON file. Also, was this fix only applied to production or was it also applied to developer preview?? We were testing developer preview and it is still failing?? Below is the request and response we are still getting in developer preview

Request sent

{

  "entityType": "individual",

  "taxpayerIdentificationNumber": "000791271",

  "nationalProviderIdentifier": "0123456794",

  "performanceYear": 2018,

  "measurementSets": [

    {

      "category": "quality",

      "submissionMethod": "registry",

      "performanceStart": "2018-01-01",

      "performanceEnd": "2018-12-31",

      "programName": "mips",

      "measurements": [

        {

          "measureId": "438",

          "value": {

            "isEndToEndReported": true,

            "strata": [

              {

                "performanceMet": 400,

                "performanceNotMet": 73,

                "eligiblePopulationException": 5,

                "eligiblePopulationExclusion": 2,

                "eligiblePopulation": 480,

                "stratum": "notOccurrence"

              },

              {

                "performanceMet": 400,

                "performanceNotMet": 173,

                "eligiblePopulationException": 5,

                "eligiblePopulationExclusion": 2,

                "eligiblePopulation": 580,

                "stratum": "hypercholesterolemia"

              },

              {

                "performanceMet": 400,

                "performanceNotMet": 273,

                "eligiblePopulationException": 5,

                "eligiblePopulationExclusion": 2,

                "eligiblePopulation": 680,

                "stratum": "diabetes"

              }

            ]

          }

        }

      ]

    }

  ]

}

Response received:

{

  "error": {

    "type": "ValidationError",

    "message": "invalid submission object",

    "details": [

      {

        "message": "field 'value' in Submission.measurementSets[0].measurements[0] is invalid: {\"isEndToEndReported\":true,\"strata\":[{\"performanceMet\":400,\"performanceNotMet\":73,\"eligiblePopulationException\":5,\"eligiblePopulationExclusion\":2,\"eligiblePopulation\":480,\"stratum\":\"notOccurrence\"},{\"performanceMet\":400,\"performanceNotMet\":173,\"eligiblePopulationException\":5,\"eligiblePopulationExclusion\":2,\"eligiblePopulation\":580,\"stratum\":\"hypercholesterolemia\"},{\"performanceMet\":400,\"performanceNotMet\":273,\"eligiblePopulationException\":5,\"eligiblePopulationExclusion\":2,\"eligiblePopulation\":680,\"stratum\":\"diabetes\"}]} is invalid for measureId 438",

        "path": "$.measurementSets[0].measurements[0].value"

      },

      {

        "message": "field 'performanceMet' in Submission.measurementSets[0].measurements[0] is missing",

        "path": "$.measurementSets[0].measurements[0].value.performanceMet"

      },

      {

        "message": "field 'eligiblePopulation' in Submission.measurementSets[0].measurements[0] is missing",

        "path": "$.measurementSets[0].measurements[0].value.eligiblePopulation"

      }

    ]

  }

}

[Sarah White]

Measure 438 is a single performance rate. The QRDA3 conversion reconciles the confusion surround the eCQM version of the measure. If submitting 438 via QPP JSON as a registry measure, then it is single performance rate. You should follow the measure specification for how to create the performance rate. If you have specific questions about that, please contact the QPP Help Desk at Q...@cms.hhs.gov.

Sarah White

Business Analyst

Nava

To view this discussion on the web visit https://groups.google.com/d/msgid/qpp-apis/6b472851-51f6-4674-81c2-7434602f5292%40googlegroups.com.

[Sailesh Dixit]

Hi Sarah, 

The quality id assigned to this measure is 438, however, we are still submitting the eCQM version of this measure on JSON format and not the registry version. Hence, the end to end is set to true. How do we handle this situation then. Again to make sure we are on the same page, we are not utilizing registry specification to  submit CMS347. The reason we have to select 438 is because JSON format only accepts quality ID and not the emeasure id. 

Please clarify. 

Best regards,

Sailesh

On Friday, February 8, 2019 at 5:06:33 PM UTC-5, Sarah White wrote:

Measure 438 is a single performance rate. The QRDA3 conversion reconciles the confusion surround the eCQM version of the measure. If submitting 438 via QPP JSON aos a registry measure, then it is single performance rate. You should follow the measure specification for how to create the performance rate. If you have specific questions about that, please contact the QPP Help Desk at Q...@cms.hhs.gov.

[Sarah White]

Hi Sailesh,

If you're not converting it through the conversion tool and instead just submitting it via QPP JSON, then it's still a single performance rate measure. You should contact CMS about using the eCQM measure specification to create a single performance rate. This is a policy question and not an API question. 

Sarah White

Business Analyst

Nava

To view this discussion on the web visit https://groups.google.com/d/msgid/qpp-apis/d0a59faf-ed9d-43a4-9234-4044c58d762e%40googlegroups.com.

[Sailesh Dixit]

Thank you sarah for the clarification and your timely response. I apprecaite it.