Thank you for your inquiry about CMS137v13 (performance period 2025). We appreciate your feedback on the codes in the "Substance Use Disorder Treatment" 2.16.840.1.113883.3.464.1003.106.12.1005 value set. This feedback will be reviewed for future consideration. The intent of the measure's Initial Population criteria is to capture patients who are diagnosed with a new episode of substance use disorder (SUD) during a visit that occurs between January 1 and November 14 of the measurement period. As stated in the definition section of the measure header, a new SUD is defined as: "The new SUD episode is the first encounter during the Intake Period with a diagnosis of SUD with no encounter or medication treatment for a diagnosis of SUD in the 60 days prior." The logic should look for a 60-day lookback period starting on the day before start of FirstSUDEpisode. Please see snippet of the CQL logic below. Please refer to the measure specification to review the measure requirements: https://ecqi.healthit.gov/sites/default/files/ecqm/measures/CMS137v13.html . If you have questions about reading the measure specification or understanding data 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-resources&global_measure_group=eCQMs . .... union ( ( ["Medication, Order": "Substance Use Disorder Long Acting Medication"] union ["Medication, Order": "Substance Use Disorder Short Acting Medication"] ) SUDMedication with "First SUD Episode During Measurement Period" FirstSUDEpisode such that SUDMedication.authorDatetime 60 days or less before day of start of FirstSUDEpisode.relevantPeriod )

Our network is experiencing challenges associated with the limited numerator-satisfying criteria. The most apparent issue is that the current value set for "Substance Use Disorder Treatment" 2.16.840.1.113883.3.464.1003.106.12.1005 does not include SBIRT (AUDIT-C/DAST10/CRAFFT) CPT (99408/99409) or HCPCS codes (G0396/G0397/H0050) to satisfy initiation of treatment. Using the SBIRT is a evidence-based practice and a recommended standard of care for primary care providers, and is widely adopted in the community health center landscape. We are aware that some population health / eCQM aggregators are mapping structured data to satisfy initiation, and this may include mapping SBIRT screeners to the comparable SNOMED codes, but our goal is to reduce interpretation and remove the need to make assumptions, which we believe to be the intent of the eCQM. Second, it seems that the measure logic fails to identify medications filled outside of the 60 day lookback period, even when the quantities overlap some or all of the 60 lookback period, as initial population exclusions. Could the ONC please confirm this is accurate and intentional?