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Thank you for your inquiry for CMS156v12: Use of High-Risk Medications in Older Adults. Responses to your inquiries can be found below:

Patients are attributed to providers based on the qualifying visit during the measurement period and assigned to numerator membership based on prescriptions ordered during the measurement period regardless of provider and if they are on the same EHR system. If a patient has a qualifying visit with provider B, but has at least two orders of high-risk medications from the same drug class (per numerator specifications) from any providers, e.g., provider A, that patient would still be included in the numerator for provider B. The logic as it currently stands does not tie prescription orders to specific providers from the qualifying denominator encounter. Meaning, even though provider B did not order/prescribe any high-risk medications, the patient would still fall into the numerator because of the previous orders within their file.

If a patient has a qualifying visit with provider B and has two orders of high-risk medications from the same drug class from a different provider, but they do not share the same EHR system, then that patient would not be included in the numerator, because provider B would only have documentation of the medication list and no orders in their system.

The measure as currently designed represents a stricter patient safety standpoint where two orders for the patient meets numerator compliance regardless of providers. The intent is also care-coordination where a provider of a different specialty who diagnose a contraindication should alert another provider of that contraindication.

We appreciate your questions and are considering re-evaluating the feasibility of adding more provider level specificity to a future version of the measure.

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Thank you for your inquiry for CMS156v12: Use of High-Risk Medications in Older Adults. Responses to your inquiries can be found below: Patients are attributed to providers based on the qualifying visit during the measurement period and assigned to numerator membership based on prescriptions ordered during the measurement period regardless of provider and if they are on the same EHR system. If a patient has a qualifying visit with provider B, but has at least two orders of high-risk medications from the same drug class (per numerator specifications) from any providers, e.g., provider A, that patient would still be included in the numerator for provider B. The logic as it currently stands does not tie prescription orders to specific providers from the qualifying denominator encounter. Meaning, even though provider B did not order/prescribe any high-risk medications, the patient would still fall into the numerator because of the previous orders within their file. If a patient has a qualifying visit with provider B and has two orders of high-risk medications from the same drug class from a different provider, but they do not share the same EHR system, then that patient would not be included in the numerator, because provider B would only have documentation of the medication list and no orders in their system. The measure as currently designed represents a stricter patient safety standpoint where two orders for the patient meets numerator compliance regardless of providers. The intent is also care-coordination where a provider of a different specialty who diagnose a contraindication should alert another provider of that contraindication. We appreciate your questions and are considering re-evaluating the feasibility of adding more provider level specificity to a future version of the measure.
2024 Performance Period EC eCQMs:

CMS0156v12

Hi,

Would you clarify which providers are to be counted in this measure?

I recognize that eCQM use a different source page to direct data inclusion but it is more vague. The company working with us to collect this data (eCQM) interpret the measure in a way that all medications a patient has ever been prescribed and that are listed on the patient's current medication list, whether prescribed by other providers, including those in other specialities and practices, which are documented on the medication list, should be attributed to every provider that sees the patient as being ordered by that provider, whether ordered by them or not, whether in their speciality or practice or not, should be included in their numerator. For example:

Provider A (primary care or speciality other than provider A - different practice) prescribes/orders a high risk medication.

Provider B sees patient, does not prescribe or order any medications, including high risk medications. Complete medication list is documented as part of patient's medical record, including medications prescribed and managed by all providers and documents 2 high risk medications prescribed by provider A but has not and does not ever order or prescribe these medications. High risk medications are out of provider B's specialty and scope of practice and clearly attributable to being ordered by provider A.

Should the patient be included in the numerator of patient B who has not ordered or prescribed these high risk medications and is a different specialty and practice from Provider A?

Should high risk medications prescribed or ordered by other providers outside one's practice be included in the tracking for this measure for Provider B or should it be the provider who ordered/prescribed the medication?

In MIPS CQM it clearly states on the the CMS website and measure description that when calculating the Numerator (submission criteria 1) and Numerator (submission criteria 2) that:

"If the patient had a high-risk medication previously prescribed by another provider, they would not be counted towards the numerator unless the submitting provider also ordered a high-risk medication for them from the same drug class" (AMA, version 7, November 2022 pg 2

"The intent of the numerator is to asses if the patient has been ordered at least two high-risk medications from the same drug class, ..., on different dates of service. The intent of the measure is to assess if the submitting provider ordered the high-risk medication (s). If the patient had a high-risk medication previously prescribed by another provider, they would be counted towards the numerator unless the submitting provider also ordered a high-risk medication from them from the same class."

This intent and consideration seem clearly explained on the MIPS CMS instructions and I am unclear as to why the company is telling me that eCQM collection utilizes a different interpretation that can affect both "logic and results" regarding the measure. Shouldn't the rules be the same? Shouldn't the data collected be the same regardless of the method, especially when the results are being compared against a sum from all data collected for the measure and have the potential to be significantly different based on different interpretations of the measure.

I understand monitoring high-risk medications in the elderly and the importance of using the medications of other providers in one's medical decision making when considering ordering or prescribing additional medications. If a provider orders or prescribes the medications, then measure makes sense.

The company quotes this section "

* _Any point at which a provider orders high-risk medications for a patient represents an opportunity to review the patient's medications to ensure they are not placed on high-risk medications inappropriately."_

With their interpretation as "ordered" meaning listed on medication list, I do not understand how any physician/provider is supposed to affect the prescribing of high risk medications prescribed by other physicians/providers if they are prescribed by other providers whose specialty is outside the specialty/scope of practice and at different medical practice/company. It would be considered malpractice for a physician/provider to "review the patient's medications to ensure are not placed on high-risk medications inappropriately" when they are prescribed by other providers for conditions they are not treating (based on the solely on presence of the medication on the list of current medications), especially when they are prescribed by providers that are practicing specialties of medications that are outside one's scope of practice. All one can do is to review the list for the presence of high risk medications in a patient's currrent medication list to inform additional medication prescription (along with drug to drug interactions, SE, cumulative effect of medications, etc.).

Any help to clarify this issue is greatly appreciated.

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