We are seeking clarification on how to interpret the CMS136 measure logic for determining the Index Prescription Start Date (IPSD). The specification states: “IPSD is the earliest prescription date for an ADHD medication where the date is in the Intake Period and the patient is not actively on ADHD medication during the 120 days prior.”

Clarification needed: When evaluating whether a patient was “actively on ADHD medication” during the 120 days prior to the IPSD, should we consider patient-reported / externally sourced medication history as evidence that the patient was on ADHD medication, or should this lookback be limited only to ADHD medications that are prescribed/recorded by our organization (e.g., orders/e-prescriptions/dispense events captured in our system)?

For our workflow, “patient-reported / externally sourced” may include items such as: medication history provided verbally by the patient, medications documented as “historical,” prior prescriptions from an outside provider listed in the medication list, imported medication history (e.g., HIE/pharmacy history), or other non–organization-prescribed sources.

Example scenario: A patient is new to our practice and receives an ADHD prescription from our provider during the Intake Period. During intake, the patient reports they were previously prescribed (and may have been taking) an ADHD medication by an outside provider within the prior 120 days, but we do not have an in-system prescription/order for that prior medication.

Question: In this scenario, should the patient be considered “actively on ADHD medication” in the 120-day lookback (thereby potentially disqualifying the new prescription from being the IPSD), based solely on patient-reported/external medication history? Or should the “actively on” determination be based only on qualifying ADHD medication prescriptions/dispense events captured as structured data that meet the measure’s medication criteria?