eCQM 238 (Use of High-Risk Medications in Older Adults)

Context: eCQM 238 requires the use of supply, dosage, and frequency to determine whether or not a patient qualifies for the numerator. Because this is an inverse measure, we want to ensure that practices are not given a better score for this measure if we are unable to evaluate numerator criteria fully due to missing or incomplete medications data.
 
Question: If a patient meets the denominator criteria for this measure, but they do not have sufficient data to be evaluated for the numerator, can we by default include the patient in the numerator to avoid overcounting patients in numerator not met for this inverse measure?
In other words, we are looking for guidance around whether or not it is appropriate to credit a practice/provider for this measure (exclude patient from numerator since it's an inverse measure) due to a lack of complete medication data from an EHR.
 
Thank you in advance for your consideration, and do not hesitate to reach out if additional information is needed.
 
Emily Lang
Verana Health