Clarification Request: CMS506 – Handling of PAC Discharges, Signed & Held Orders, and PRN RxNorm Code

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    • Type: Hosp Inpt eCQMs - Hospital Inpatient eCQMs
    • Resolution: Answered
    • Priority: High
    • Component/s: None
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      Thank you for your questions/concerns regarding CMS506v7, Safe Use of Opioids - Concurrent Prescribing. Please see below for responses to your questions:

      1. Inclusion of Patients Discharged to Post-Acute Care (PAC) Facilities: Can these settings be excluded in future versions of the measure, or clarified in existing logic/specs?

      CMS506 was originally tested and endorsed without excluding patients transferred to post-acute care facilities. We will consider testing the measure for this population in the future.

      2. Inclusion of Signed and Held Discharge Orders: Can CMS clarify how signed and held (but undispensed) orders should be handled in logic, and whether guidance can be issued to EHR vendors?

      For signed and held discharge orders, if a medication is included in a list at discharge but the patient will not be discharged on it or will not be taking it, and therefore, should not be counted in the numerator, we suggest working with your EHR vendor to differentiate these medications from those the patient is or will be taking on discharge.

      3. PRN Orders for the Same Medication at Different Pain Levels: Can CMS clarify whether this logic is intended, and consider refining specs to distinguish clinically appropriate flexibility from unsafe concurrent use?

      As you noted, medications are considered distinct when they have different RXNORM codes. We recognize that there are some clinically appropriate situations for concurrent opioids prescriptions, and do not expect hospitals to have a score of zero.
      Show
      Thank you for your questions/concerns regarding CMS506v7, Safe Use of Opioids - Concurrent Prescribing. Please see below for responses to your questions: 1. Inclusion of Patients Discharged to Post-Acute Care (PAC) Facilities: Can these settings be excluded in future versions of the measure, or clarified in existing logic/specs? CMS506 was originally tested and endorsed without excluding patients transferred to post-acute care facilities. We will consider testing the measure for this population in the future. 2. Inclusion of Signed and Held Discharge Orders: Can CMS clarify how signed and held (but undispensed) orders should be handled in logic, and whether guidance can be issued to EHR vendors? For signed and held discharge orders, if a medication is included in a list at discharge but the patient will not be discharged on it or will not be taking it, and therefore, should not be counted in the numerator, we suggest working with your EHR vendor to differentiate these medications from those the patient is or will be taking on discharge. 3. PRN Orders for the Same Medication at Different Pain Levels: Can CMS clarify whether this logic is intended, and consider refining specs to distinguish clinically appropriate flexibility from unsafe concurrent use? As you noted, medications are considered distinct when they have different RXNORM codes. We recognize that there are some clinically appropriate situations for concurrent opioids prescriptions, and do not expect hospitals to have a score of zero.
    • CMS0506v7
    • These issues may inflate our numerator and misrepresent performance, creating confusion for clinical and informatics teams and making it harder to validate data and guide safe prescribing practices.

      We are requesting clarification on three issues related to the CMS506 Safe Use of Opioids – Concurrent Prescribing measure. These issues are impacting our reporting and alignment with clinical practice.

      1. Inclusion of Patients Discharged to Post-Acute Care (PAC) Facilities
      Per guidance in CQM-7736, discharges to inpatient care are excluded from CMS506. However, discharges to SNFs, IRFs, and LTACHs are still being included in the numerator. These are clinically supervised environments, and including them may not reflect the intent of reducing outpatient prescribing risk.
      Request: Can these settings be excluded in future versions of the measure, or clarified in existing logic/specs?

      2. Inclusion of Signed and Held Discharge Orders
      Some EHR systems are including signed and held discharge orders in the numerator, even when the medications are not dispensed to the patient. This concern was raised in CQM-7951, and has been observed across multiple organizations.
      Request: Can CMS clarify how signed and held (but undispensed) orders should be handled in logic, and whether guidance can be issued to EHR vendors?

      3. PRN Orders for the Same Medication at Different Pain Levels
      PRN orders for the same opioid, written for different pain levels (e.g., moderate vs. severe), are counted separately—likely due to different RxNorm codes. Clinically, these are appropriate practices for flexible pain management, not duplicative prescribing.
      Request: Can CMS clarify whether this logic is intended, and consider refining specs to distinguish clinically appropriate flexibility from unsafe concurrent use?

            Assignee:
            Mathematica EH eCQM Team
            Reporter:
            Zobeida Torres (Inactive)
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