This is addressed by the revised language for Introduction.  https://confluence.hl7.org/download/attachments/97465242/GapsInCareReporting_revised_introduction_text.docx?version=1&modificationDate=1607673158598&api=v2 Updated the definition of care gaps. "As supported in this guide, a gap in care is defined as a discrepancy between standards of care specified in quality measures and the services that were provided. Gaps in care may be identified because no care was provided, or because data about care provided is missing from the system calculating the data.".