CMS128v11 description of denominator exclusion: Patients who were actively on an antidepressant medication in the 105 days prior to the Index prescription start date.

A patient with an IPSD of 5/6/2023 was actively on an anti-depressant from 12/28/2021 to 2/4/2022 which is within 105 days prior to the IPSD of 5/6/2023. By denominator exclusion criteria outlined above in the description this patient should be excluded from the denominator. However they are not being excluded. When looking into the logic for CMS128v11 it reads that the active medication needs to also overlap the intake period in order for it to exclude the patient. The metric denominaor exclusion description makes no mention that the active medication also needs to overlap both the intake period AND the IPSD-105 days.