CDC's Comment for draft USCDI v5

CDC supports the inclusion of this data element in USCDI v5 as it is an element that may be necessary for calculation of our digital quality metrics from FHIR data.

NCPDP Comments on USCDI draft v5

NCPDP applauds the addition of SNOMED CT codes and ICD-10 as data elements code sets for Indication.

CDC's comment on behalf of CSTE for USCDI v5

 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 Consolidated Comment for USCDI v5

• ** ADD THIS USE CASE TO SUBMISSION **

1. "Medication Opioids": Unintentional injuries are the leading cause of death for Americans aged 1–44 years. The leading cause of death for unintentional injury is poisoning, specifically drug overdose. Overdose deaths continue to climb each year and accelerated during the COVID-19 pandemic. The majority of national overdose deaths involve opioids. Many patients receive their first exposure to opioids following surgery, and dentists are the leading prescriber of opioids among adolescents aged 10-19 and second-leading prescriber among young adults aged 20–29. In 2004, an estimated 3.5 million patients had wisdom teeth extracted. Filled opioid prescriptions after wisdom tooth extraction is associated with higher odds of persistent opioid use among opioid-naïve patients. Better understanding prescribing habits can help identify risk factors and particularly vulnerable populations.
2. "Medications Antibiotics": More than 2.8 million antimicrobial-resistant infections occur in the United States each year, and more than 35,000 people die as a result. When Clostridioides difficile is added to these, the US toll exceeds 3 million infections and 48,000 deaths. The threat of antibiotic resistance undermines progress in health care, food production, and life expectancy. Addressing this threat requires preventing infections in the first place, slowing the development of resistance through better antibiotic use, and stopping the spread of resistance when it develops. Research shows that dentists overuse antibiotics, particularly for patients who are underinsured. Dentists prescribe 10% of all outpatient antibiotics, although there is significant geographical variability. Better understanding prescribing practices, knowledge, and beliefs can aid in the development of meaningful antimicrobial stewardship efforts addressing case selection and areas of practice.

NACCHO supports CDC's recommendations.

NCPDP Comment

NCPDP recommends adding SNOMED CT and ICD-10 as data elements/code sets to further adhere to the standardized code lists that have been created to identify services or products provided to the patient. NCPDP SCRIPT Standard v2017071 data element “indication” uses SNOMED CT codes in the “SIG” directions for use and uses SNOMED CT codes and ICD-10 codes in the NCPDP SCRIPT Standard v2017071“Diagnosis” field.

NCPDP Comments

• NCPDP recommends adding SNOMED CT and ICD10 as data elements/code sets to further adhere to the standardized code lists that have been created to identify services or products provided to the patient. NCPDP SCRIPT standard data element “indication” uses SNOMED CT in the “SIG” directions for use and ICD10 in the NCPDP SCRIPT “Diagnosis” field.
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    "Currently, most prescriptions lack a key piece of information needed for safe medication use: the patient-specific drug indication. Integrating indications could pave the way for safer prescribing in multiple ways, including avoiding look-alike/sound-alike errors, facilitating selection of drugs of choice, aiding in communication among the healthcare team, bolstering patient understanding and adherence, and organizing medication lists to facilitate medication reconciliation. Although strongly supported by pharmacists, multiple prior attempts to encourage prescribers to include the indication on prescriptions have not been successful.” https://pubmed.ncbi.nlm.nih.gov/29674327/  

CDC's Consolidated Comment for USCDI v4

CDC continues to recommend inclusion of this high priority data element in USCDI v4

Medications Indication terminology standard

This field is for general comments on this specific data element. To submit new USCDI data classes and/or data elements, please use the USCDI ONDEC system: https://healthit.gov/ONDEC

Recommend adding SNOMED CT and ICD-10 as the terminology standards to be used for Indication data element of Medications Data Class.

CDC's Consolidated Comment

Reason for medication prescription or administration is particularly important as medications can be used for multiple conditions, and for off-label use. Documentation of the specific reason a medication is prescribed is integral to understanding a patient’s specific condition.

Collected for Tuberculosis (TB) and Latent Tuberculosis Infection (LTBI) Surveillance and are included in the TB and LTBI Message Mapping Guides (MMG). https://ndc.services.cdc.gov/mmgpage/tuberculosis-and-latent-tb-infection-message-mapping-guide/

Additional Technical Specifications: HL7 FHIR Health Care Surveys Content Implementation Guide (http://hl7.org/fhir/us/health-care-surveys-reporting/2022Jan/).

Unified Comment from CDC

• Additional Use Case: Information about medications prescribed, administered, and reasons for prescribing are collected as part of CDC's routine nationally notifiable condition surveillance for HIV, tuberculosis and sexually transmitted diseases. This information is collected to understand trends in treatment initiation and completion (as applicable), and as part of a health department's case management work.
   
• Number of stakeholders who capture, access, use or exchange this data element: All US States and DC are funded through CDC’s Division of HIV Prevention, Division of TB Elimination and Division of STD Prevention flagship Notice of Funding Actions to perform surveillance activities, including collection of these data for surveillance purposes.
   
• Healthcare Aims: Improving patient experience of care, Improving health of populations, Reducing cost of care, Improving provider experience of care
   
• Use of data element: Extensively used in production environments
   
• Exchange of data element: The Multiple Chronic Conditions eCare Plan project successfully tested this element at the Sep 2020 and Jan 2021 FHIR connectathons and has implemented it at the OHSU testing site. 
   
• CSTE supports inclusion of this measure into USCDI v3:  helpful for PH to know if treatment was administered or prescribed to indicate a need to contact patient and connect with other wraparound services/linkage to care (e.g., STIs, Hepatitis C/B)