The CMS 506 (Safe Use of Opioids – Concurrent Prescribing) eCQM specifications for both the 2025 and 2026 reporting periods reference an opioid medication value set whose name indicates inclusion of Schedule II, III, and IV medications only; however, the referenced value set expansions include Schedule V medications.

Additionally, the CMS 506 measure specifications describe the measure in the context of Schedule II, III, and IV opioid medications, with no explicit reference to inclusion of Schedule V medications.

Specifically:

• Both the 2025 and 2026 CMS 506 specifications reference the value set “Schedule II, III and IV Opioid Medications” (OID 2.16.840.1.113762.1.4.1046.241).

• The 2025 specification references the eCQM Update 2024-05-02 expansion (definition version 20240215).

• The 2026 specification references the eCQM Update 2025-05-08 expansion.

• Review of both expansions in VSAC confirms inclusion of codeine-containing products (e.g., RxNorm 995868 and 991486), which are classified as Schedule V medications.

This creates a potential inconsistency between the measure specification language, the value set name, and the contents of the referenced value set expansions. Screenshots illustrating the inclusion of Schedule V medications within the referenced value set expansions for both the 2025 and 2026 CMS 506 specifications are attached for reference.

This issue is submitted to request review and clarification of whether inclusion of Schedule V medications is intentional for CMS 506, and if not, whether future specifications or value set revisions are planned to better align the value set name and contents with the stated scope of the measure. If inclusion is intentional, any additional guidance or context that would help stakeholders interpret measure results would be appreciated.