(Not exactly a hybrid measure, but closest of the Project choices offered).

The "Use of Chronic Narcotic" data element should come from the medical record/EHR (provider reported). 

When “should” is “used in place of “must,” it usually implies some room for creativity in meeting the intent of a measure. given an entity's unique workflow, and personnel or system resources.

Therefore, we are interested in any recommendations for collection since the other PRO-PM questions are patient-reported.  In the meantime, we present the following for consideration:

The patient is providing first-hand information on their chronic pain and narcotic use whether being interviewed by a clinician or completing the PRO-PM survey themselves.  It should therefore be reasonable to allow patients to be asked and to answer the chronic narcotics question along with the other PRO-PM questions.

However, it appears the intent of requiring an evaluation by a healthcare provider is to ensure the patient understands and is answering the question correctly.

Does CMS agree therefore, that the important factor is that an evaluation of patients’ answers take place prior to data submission to CMS to ensure accurate collection, coding and reporting of the narcotic use metric?

The measure states that hospitals should rely on collection of data elements by those personnel who they determine can accurately assess and record the information required.

Does CMS also agree, then, that if a patient were to answer the chronic pain and narcotic use question themselves as part of the PRO-PM questionnaire, that this approach is acceptable as long as a hospital-approved qualified clinician reviews their medical record to validate their answers prior to data submission to CMS?

There are other reasons why this approach could be shown to be reasonable, including factors such as patients who arrive as referrals from providers who are not embedded in our system and do not interface with our EHR, and patients who may answer the PRO-PM questions in a setting that is not designed to screen or respond to their answers immediately. 

In essence, it can take some time to fully establish a patient, complete clinical assessments, and build up medical record documentation to effectuate the best evaluation of a patient's chronic pain and narcotic use.  It might be best if this process does not hold up initial completion of the PRO-PM questionnaire or have to be modified to accommodate one singular question.

Thank you very much for your time and attention.

 

Respectfully,

Nathan Currah

 

Nathan Currah, RN MBSCR

Clinical Analytics Coordinator

Quality & Safety

Enloe Medical Center

Direct: 530-332-7384

Office: 530-332-7339

Fax: 530-893-6903

nathan.currah@enloe.org