Data Element

Comment

Comment

Highly support and agree with the addition of this new data element. This will ensure patient treatment plan adherence and patient care outcomes.

NCPDP Comment

NCPDP recommends updating the data element definition to “Medication is consumed according to instructions as captured by the provider, pharmacist or clinician”. Examples include but are not limited to taking as directed, taking not as directed, and not taking.

THIA Comment on Medications: Medication Adherence

The Texas Health Informatics Alliance (THIA) Policy and Standards Working Group supports the proposal for medication adherence; however, we recognize that it is going to take a lot of time and effort to properly establish. Associated/relevant vocabulary should be clearly defined (i.e. taking as directed, not taking as directed, not taking). Medication adherence calculations should be accurate, timely, and transparent.

Medication adherence is now a metric for Primary Care Providers (PCPs). PCPs are measured by the Centers for Medicaid and Medicare Services (CMS, which affects value-based metric scores through accountable care organizations (ACOs).

How medication adherence is getting calculated should be clear. Currently, medication adherence is claims-based and it is difficult to measure within ACOs. If one’s ACO is going to utilize a certain form/method to measure medication adherence, providers want it to be accurate and timely.

Capturing the costs of medication adherence is difficult. Medications can be expensive and it is hard to know where patients get their medications from and/or if they use services, such as GoodRx.

Capturing the cadence of medication adherence is difficult. Refills count if one is done within a 6-month interval. If a patient falls off compliance, it takes about 18 months post-refill to get them back onto compliance. Notably, the patient’s physician gets dinged throughout the 18 months of “non-compliance”.

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