We are seeking clarification on the intended interpretation of the timing logic in CMS506v7 – specifically the use of the condition “author dateTime during day of inpatient encounter.” Our vendor is interpreting this to include prescriptions authored at any point on the discharge date, even after the patient’s actual discharge time.

We understand this may be a valid interpretation, but due to the ambiguity of the language, we would appreciate confirmation on whether prescriptions written after discharge time but on the same calendar day are expected to be included in the numerator.

Clarifying this will help ensure consistent application of the logic and accurate reporting across systems.

Our team is encountering discrepancies in the reporting logic for CMS506v7 – Safe Use of Opioids – Concurrent Prescribing. Based on current interpretation by our vendor (Oracle), the logic includes prescriptions written at any time on the discharge date, regardless of the actual discharge time. This interpretation is based on the phrase “author dateTime during day of inpatient encounter,” which is being read as the full calendar day, not limited by the discharge timestamp.

It’s possible that this interpretation is consistent with CMS intent; however, we are seeking clarification as the current verbiage is ambiguous and could lead to inconsistent implementations across vendors and sites. We are including a snippet of the numerator logic in this ticket to illustrate how this condition is being applied in our environment.