Safe Use of Opioids-Concurrent Prescribing:
There are no specific questions for this measure.
IPP: This is a realistic data element to capture. We would recommend that Observation be added to the Inpatient stay less than 120 days.
Denominator Exclusions: Currently Exclusions are patients with cancer or receiving palliative care, we do not find these are appropriate exclusions and would recommend the following. Patients who are a Comfort Measures Only maybe a better option. Currently, we have no specific way to exclude a patient that is seeking Palliative Care on discharge. Not all facilities have a Palliative Care staff 24/7 for a consult to take place either.
The exclusion of patients with cancer is an appropriate data element, the current referenced value set includes 5, 951 codes. This may exclude patients that are not at a level where the current treatment would include opioids and benzodiazepines. As the measure is framed now, there is no clarification if the diagnosis needs to be a Primary, Discharge, or a History of status. We would recommend that the Diagnosis code be designated as a History of Cancer, this will better capture the targeted population.

Numerator: This may be a difficult element to capture if a Hospital does not utilize electronic prescription of opioids. Alternative methods of collection may be utilized, but if this element is hard coded and not a discrete data element for hospitals to filter, this would be impossible for hospitals to capture.