Clarification Request Regarding CMS156 - High-Risk Medications for Older Adults

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    • Type: EC eCQMs - Eligible Clinicians
    • Resolution: Answered
    • Priority: Moderate
    • Component/s: None
    • None
    • Kelli Potts
    • 812450-7617
    • Deaconess Health System
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      Thank you for your inquiry about CMS156v14 (performance period 2026). Numerator 1a is met if two high-risk medications from the same drug class were ordered on different days during the measurement period, or that the medication was ordered once during the measurement period with at least one refill (to indicate two orders). Zolpidem, as well as any code included in the “Potentially Harmful Nonbenzodiazepine Hypnotics for Older Adults” value set (OID: 2.16.840.1.113883.3.464.1003.196.12.1480), may be used to satisfy Numerator 1a. The specific codes for Zolpidem Tartrate 25 mg and 50 mg in your example are not included in the value set; however, Zolpidem as an ingredient is represented in the value set. Clinically equivalent services may be mapped to the codes in the value set. If mapping is done, you should maintain documentation in case of a CMS audit. In your example, if a patient had Zolpidem ordered on 1/1/2026 and again on 2/5/2026, this would meet the criteria for Numerator 1a.

      We are unable to provide guidance on clinical workflows or how these events should be documented in the EHR. We recommend consulting your EHR vendor and clinical partners for workflow specific recommendations.

      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.

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      Thank you for your inquiry about CMS156v14 (performance period 2026). Numerator 1a is met if two high-risk medications from the same drug class were ordered on different days during the measurement period, or that the medication was ordered once during the measurement period with at least one refill (to indicate two orders). Zolpidem, as well as any code included in the “Potentially Harmful Nonbenzodiazepine Hypnotics for Older Adults” value set (OID: 2.16.840.1.113883.3.464.1003.196.12.1480), may be used to satisfy Numerator 1a. The specific codes for Zolpidem Tartrate 25 mg and 50 mg in your example are not included in the value set; however, Zolpidem as an ingredient is represented in the value set. Clinically equivalent services may be mapped to the codes in the value set. If mapping is done, you should maintain documentation in case of a CMS audit. In your example, if a patient had Zolpidem ordered on 1/1/2026 and again on 2/5/2026, this would meet the criteria for Numerator 1a. We are unable to provide guidance on clinical workflows or how these events should be documented in the EHR. We recommend consulting your EHR vendor and clinical partners for workflow specific recommendations. 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 .
    • CMS0156v14

      I am reaching out for clarification regarding CMS156 (High-Risk Medications for Older Adults), specifically related to how medication orders are counted within the measure.
       
      My understanding is that the measure identifies patients who were ordered at least two high‑risk medications from the same drug class during the measurement period. I would like to ensure I am interpreting this correctly so that I can accurately educate our clinic teams.
      I am seeking clarification on the following scenario:
       
      If a patient has an existing order for a high‑risk medication that is later discontinued and reordered at a different dosage, does this scenario count as two high‑risk medication orders within the same drug class, or is it treated as one continuous medication order?
       
      Example: * 1/1/2026: Patient is prescribed Zolpidem Tartrate 25 mg

      • 2/5/2026: The order is discontinued
      • 2/5/2026: A new order is written for Zolpidem Tartrate 50 mg

       
      Would this be considered: * Two orders for high‑risk medications (and therefore negatively impact the measure), or

      • A single medication order with a dosage adjustment (and therefore not counted twice)?

       
      Thank you in advance for your guidance. I want to ensure that we are applying the measure specifications correctly and providing accurate education to our clinics.

            Assignee:
            AIR EC eCQM Team
            Reporter:
            Kelli Potts
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