Hello,

We are seeking clarification regarding the timing requirements for evaluating “Treatment for Opioid Use Disorders” (MAT/MOUD) events in relation to the Measurement Period.

Currently, we evaluate Treatment for Opioid Use Disorders events when the treatment date/time occurs during the inpatient encounter period (InpatientEncounter.relevantPeriod) and within the defined Measurement Period for the reporting year (for example, January 1, 2026 – December 31, 2026). In other words, if a qualifying MAT/MOUD treatment occurs at any time during the inpatient encounter and falls within the reporting year’s Measurement Period, it is considered valid for the measure.

For example, our current evaluation aligns with logic similar to the following:

However, during the 2025 reporting submissions, we received feedback indicating that according to the CMS specifications, Treatment for Opioid Use Disorders should only qualify when the treatment date occurs during the day of the Measurement Period.

Because quarterly submissions are used operationally for reporting, this interpretation raises questions when encounters span across quarters.

Example Scenario:
Event                                                         Date
Inpatient Encounter Start                          March 30
MAT/MOUD Medication Administered     March 31
Inpatient Encounter Discharge                  April 2

We believe the MAT/MOUD medication would qualify because it occurs during the inpatient encounter period and within the Measurement Period for the reporting year.

Based on the feedback we received, the expectation appears to be that MAT/MOUD medications should only qualify if they occur within the same reporting quarter as the encounter discharge, since submissions are performed quarterly.

We would appreciate clarification on the following:
1. For the provided scenario, should the MAT/MOUD treatment qualify the patient for denominator exclusion?
2. When submitting data quarterly, should MAT/MOUD treatments that occur in a different quarter than the encounter discharge be excluded from evaluation even if they occurred during the encounter and within the reporting year’s Measurement Period?