Thank you for your inquiry about CMS138v13 (performance period 2024). This measure contains three reporting rates, which aim to identify: patients who were screened for tobacco use (rate/population 1), patients who were identified as tobacco users and received a tobacco cessation intervention (rate/population 2), and a comprehensive look at the overall performance on tobacco screening and cessation intervention (rate/population 3). The USPSTF references the US Food and Drug Administration definition of tobacco, which includes e-cigarettes, hookah pens and other electronic nicotine delivery systems. E-cigarettes and/or Vaping products usually contain nicotine, which is the addictive ingredient in tobacco. However, E-cigarettes and vaping products are not always classified as "smokeless tobacco" since substances other than tobacco can also be used in these products. Pharmacotherapies like nicotine patches and gum are not considered tobacco use by itself, per the 2021 USPSTF recommendation on tobacco use. Therefore, if a patient is on nicotine patches or gum during their annual tobacco screening, but does not use any other tobacco products, they will not qualify for the second reporting rate that is limited to those identified as tobacco users. Additionally, this patient would not qualify for a positive numerator for rate 3, though pharmacotherapy nicotine gum and patch use qualify as tobacco cessation, because this rate is also limited to those identified as tobacco users in numerator 1 and 2. If you have questions about understanding measure requirements, you may refer to the "Guide for Reading eCQMs" for additional guidance. If you have questions regarding implementing the measure, you may refer to the "Implementation Checklist for eCQM Annual Update" for additional guidance. These resources can be found in the eCQI Resource Center: https://ecqi.healthit.gov/ep-ec?qt-tabs_ep=ecqm-

We are unclear on when if-ever, to include a patient who vapes or uses any form of nicotine in the denominator. The guidance seems to state to include a patient who vapes any trace amount of nicotine because its an addictive substance derived from tobacco but not to include patients who use nicotine patches or nicotine gum, which is also confusing. Also, seems to state we should not included vaping, if its a substance other than nicotine. We are having trouble understanding the clinical workflow recommendation and rationale which seems to be in conflict regarding the method by which nicotine enters the body.