Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.

Data Element

Medication Administration

Comment

CSTE Comment - v5

Medication data is critical for exchange with public health and is included in eCR standards. It is especially important for STI programs, HIV and TB surveillance as well as for public health response and surveillance for antimicrobial resistant pathogen infections.   CSTE also strongly agrees that the ability to exchange data on prescribing of opioid medications in particular is of great importance to public health programs which aim to reduce opioid overdoses and deaths.

CDC's Comment for draft USCDI v5

CDC-CMS Joint Priority Data Element. 

See letter here (submitted on 1/29/2024): https://www.healthit.gov/isa/sites/isa/files/2024-02/FINAL_CDC%20and%20CMS-CCSQ%20Joint%20USCDI%20v5%20submission%20letter_012924.pdf

Please Include Medication Administration in USCDI v5

Vizient recommends adding the Medication Administration data element to USCDI v5 as this element allows for further insight and analyses of which medications were administered within visits.

FDA Joint Support for Medication Administration in USCDI v5

Posting as a member of the FDA USCDI Working Group: we are re-iterating the multiple requests to add support for distinction of medical records of the Administration of Medications to patients.  US Core, as an approximate representation of USCDI in HL7 FHIR, currently has made "must support" requirements for use of MedicationRequest (for records of requests/prescriptions of medications) and MedicationDispense (for pharmacy dispensing of a medication).  It is still surprising that USCDI continually omits the final ubiquitous type of record for patient medications, one which when it exists is the most definitive proof that a person has a medication in their body.  

Please refer to my previous comment in strong support with a range of justifications of this in 2022: https://www.healthit.gov/isa/comment/11701

Further, over the past four years in addition to FDA, repeated support for inclusion of this in USCDI has come in comments to this request from multiple agencies (CDC, CMS) and public health organizations (CSTE, NACCHO), and FHIR developers.  (see multiple comments here: https://www.healthit.gov/isa/uscdi-data/medication-administration )

As part of the Vulcan FHIR Accelerator work on real world data (RWD) use in clinical research, it was found that the requirement of consistent standardized use of FHIR for Medication Requests, Dispensation, Administration, and Statements was critical to assess how clearly one can determine the medication status of a patient (currently using, periodic use, previously used, etc).  The Vulcan RWD FHIR Implementation Guide for this work ( https://build.fhir.org/ig/HL7/vulcan-rwd/index.html ) was published in May 2023.   During IG testing at FHIR connectathons a participant data providers even found the transformation of Medication Administration Records from legacy or proprietary standards to be relatively non-burdensome, demonstrating the feasibility of this inclusion in USCDI for EHRs.

Cerner also appears to be supporting this in their implementations: https://fhir.cerner.com/millennium/r4/clinical/medications/medication-administration/ suggesting this will be a low level of effort for adoption.

Please consider this inclusion in support of healthcare and public health with downstream benefits for clinical research and pharmaceutical development

CDC and CMS-CCSQ Joint Support for Medication Administration

Thank you for opportunity to comment on this data element. The Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC) emphasize the importance of patient safety being reflected in the USCDI standards. As an integral aspect of patient safety, medication management is critical to patient care and coordination between providers, and related quality and public health enterprises. Medication administration, specifically, is a critical concept for CMS and CDC programs that support quality improvement and public health surveillance. We continue to emphasize the need for greater specificity in the USCDI Medications data class. The medications data class in USCDI is currently inadequate to support patient safety, quality improvement, or public health. The medication data elements do not differentiate among medications that are active, ordered, and administered/prescribed to the patient. Given these complexities, more clarity and structure are necessary in this data class to accurately evaluate and provide clinical care and promote patient safety. CMS and CDC strongly recommend the Medication Administration (Level 2)/Medication Administered Code (Level 0) in the Medications data class be added to USCDI.

Support for Medication Administration

Lantana Consulting Group supports the CDC/CMS-CCSQ recommendation and emphasizes the important role these data elements play in supporting patient safety. 

CDC's Consolidated Comment for USCDI v5

  • Medication Administration is an available API by some of the major vendors that operate in the United States as well as in the Netherlands. However, the use of the API has been restricted to their Netherlands users. Med administration is a separate function for most EHRs in bar code medicationadministration and the Medication resource is not distinguishing that specific functionality in its current data capture.
  • CSTE Comment: CSTE agrees with CDC's recommendation for this data element. 
  • NACCHO Comment: Supports CDC"s recommendation.

Please Include Medication Administration in USCDI v4

Vizient recommends adding the Medication Administration data element to USCDI v4 as this element allows for further insight and analyses of which medications were administered within visits.

CMS-CCSQ/CDC Joint USCDIv4 Priority - Medication Administration

We continue to urge adding more specificity to the USCDI Medications Data Class. These medication data elements are necessary for understanding adverse drug events, opioid use and misuse, and medication access. Medication administration, along with medications prescribed, discharge medications, medication administration route, medication administration dose, and medication administration date and time serve the ONC USCDI v4 stated priorities related to mitigating health inequities and disparities, addressing needs of underserved populations, and addressing public health reporting needs.

CMS-CCSQ/CDC Joint USCDIv4 Priority - Medication Administration

We continue to urge adding more specificity to the USCDI Medications Data Class. These medication data elements are necessary for understanding adverse drug events, opioid use and misuse, and medication access.  serve the ONC USCDI v4 stated priorities related to mitigating health inequities and disparities, addressing needs of underserved populations, and addressing public health reporting needs.

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