​​Thank you for your question on CMS506, Safe Use of Opioids - Concurrent Prescribing. ​Patients discharged to other acute inpatient facilities, as defined in the value set "Discharge To Acute Care Facility" (OID 2.16.840.1.113883.3.117.1.7.1.87), are excluded. This value set includes community hospitals, tertiary referral hospitals, and acute care hospitals. Patients transferred to a skilled nursing facility, rehabilitation facility, or LTAC hospital are not excluded. We appreciate your input and will consider these exclusions in future versions of the measure.

When we transfer surgical patients to rehab or nursing homes for rehab, the surgeon's transfer medication list includes two different doses of an opioid with instructions for choosing the dose based on the patient's pain level (e.g. oxycodone 10mg; oxycodone 5mg). Since the two different dosages have two different RxNorm codes (e.g. 1049683; 1049621), they are picked up as two different opioids. Since rehab and nursing home transferred patient are not excluded these transfer meds are used to put the patient into the numerator even though the medications are being administered as prescribed by facility staff. When the patients are discharged from Rehab to home, they are kept on only one dose. Conceptually this is inaccurate capture of 2 or more opioids from a safety standpoint.