Thank you for the opportunity to provide feedback on the proposed eCQM CMS460: Potential Opioid Overuse. As an EHR vendor we recognize the need to collect data in this domain and appreciate this opportunity to contribute to the fight against the opioid epidemic. We want to assist CMS and public health organizations in their efforts to collect data to reduce the number or opiates prescribed and drive continuous care and quality improvement. To achieve these goals, Foothold Technology offers the following feedback on the proposed quality measure:

• Encouraging reconciliation would be beneficial for care and data collection for the measure. Not all opiates will be prescribed by the physician tracking this measure, but all physicians can keep track of medications prescribed and integrate them into a client’s record, encouraging a greater reporting rate. Contributing this data should be encouraged rather than the spectre of the stigma of having a patient with a high dosage opiate in their record (which could encourage a provider to suppress this information even if they didn’t prescribe the opiate. We suggest that the creation of an alternate population measure to credit providers who perform reconciliation on a client’s record that includes a high dosage opiate.

• Medications are coded into an EHR primarily using a RxNorm code, which generally consists of a medication name and includes a strength and unit. We would encourage the usage of a VSAC OID that contains all medications considered the equivalent of an “an average daily dosage of 90 milligram morphine equivalents or greater” and instead of tracking Medication names by RxNorm and utilizing discrete strength and unit fields. Our thinking is that MME is not a typical unit field and would be difficult to track across different examples of CEHRT and would be challenging to incorporate across systems.

• The clinical recommendation states: “Clinicians should evaluate benefits and harms with patients within 1 to 4 weeks of starting opioid therapy for chronic pain or of dose escalation. Clinicians should evaluate benefits and harms of continued therapy with patients every 3 months or more frequently. If benefits do not outweigh harms of continued opioid therapy, clinicians should optimize other therapies and work with patients to taper opioids to lower dosages or to taper and discontinue opioids.” However this is not addressed in the quality measure numerator, nor are alternative to high dose opiates. We would encourage the creation of an alternate population measure to reward physicians for secondary follow-up and alternatives to opiates interventions.

Thank you for your consideration, Foothold Technology looks forward to supporting this Quality Measure upon its release.