The American Medical Association (AMA) appreciates the opportunity to comment on the Safe Use of Opioids – Concurrent Prescribing eCQM. The AMA does not believe that this measure will truly drive improvements in care and may result in unintended negative consequences for patients, hospitals sand physicians.

Specifically, as we stated in previous comments, the measure as currently defined lacks the precision needed to ensure that only those patients for whom concurrent prescribing of two or more opioids or an opioid and benzodiazepine are included in the denominator. The patient population could likely include patients for whom concurrent prescribing of these medications may be appropriate, particularly those with chronic pain. Without further refinement, the AMA believes that there is a significant risk for the performance of hospitals and their physicians to be inaccurately represented. More importantly, there is a substantial risk that patients for whom these medications may be warranted will not receive appropriate therapies, leading to potential adverse outcomes, including depression, loss of function and other negative unintended consequences.

The AMA believes that quality measurement needs to focus on how well patients’ pain is controlled, whether functional improvement goals are met, and what therapies are being used to manage pain. If pain can be well controlled and function improved without the need of these concurrent medications, then that is an indication of good patient care but the measure must precisely define the patients for which it is appropriate. We do not believe that this measure as specified is an appropriate goal as it may leave patients without access to needed therapies.

At this time, the developer has not provided sufficient data to demonstrate that the measure will capture only those patients for whom concurrent prescribing is not appropriate nor does the submission provide adequate evidence to demonstrate that use of this measure will drive improvements in patient care without also creating potentially negative unintended consequences. The AMA supports addressing the opioid crisis through quality measurement in addition to other avenues but strongly believes that any measures that are used by CMS in federal programs must also demonstrate that it does not compromise patient care.