Yes. All members who are numerator compliant for Rate 1 must be used as the eligible population for Rate 2 in both the SPC and SPD measures (regardless of the data source used to capture the Rate 1 numerator). For example, if supplemental data were used to identify compliance for the Rate 1 numerator, then supplemental data will be included in identifying the Rate 2 eligible population.
If pharmacy data are the source data, and are treated similar to encounter data, they could be classified as encounter data rather than as supplemental data. For example, if a pharmacy benefit manager (PBM) offers the pharmacy benefit on behalf of a health plan and regularly sends pharmacy data to the plan in a standard format, the data could be considered to be encounter data. Organizations must work with their auditor to determine how data are classified. The auditor will review the organization’s pharmacy benefit structure and the processes for receiving and using data when determining the classification.
HEDIS 2016