Medications

CDC's support for CMS comment for USCDI v7

CDC supports CMS CCSQ recommendation for the Medication Administration Patient data element be advanced to Level 2 and added to final USCDI v7.

CMS-CCSQ Supports Medication Admin Patient for USCDI v7

Recommendation: CMS CCSQ recommends the Medication Administration Patient element be advanced to Level 2 and added to final USCDI v7 in support of the CDC’s recommendations.

Rationale:  CMS CCSQ recommends inclusion of the Medication Administration Patient data element into USCDI v7 since this data element, and others related to medication administration, is important for medication reconciliation and continuity of care, especially during transitions of care between acute and post-acute settings. The Medications data class lacks the necessary detail to effectively differentiate between active, ordered, or administered medications, which hampers accurate clinical evaluation and patient safety. Medication administration is a key priority for CMS and the Centers for Disease and Control Prevention (CDC) programs as its essential for quality improvement and public health surveillance as part of the HL7 NHSN dQM Reporting Implementation Guideline. Adding the data element Medication Administration Patient to USCDI v7 will support a more comprehensive exchange of medication information.  Other data elements in USCDI are not adequate to capture the required medication administration data.  We concur with the CDC that Procedure Time is not intended to capture medication data and have found no evidence that medication administration instances can be reliably identified through its use in the Procedures data class.  The current Medication data element fails to differentiate between medication requests, administrations, and dispensing activities.  MedicationRequest represents orders and prescriptions, but does not reflect that a medication has actually been administered to a patient, limiting insight into changes or cancellations to medication orders and their implications for patient care.  Relevant use cases include patients receiving medications during inpatient stays, highly complex and vulnerable patients who is dependent on medication and whose care must be coordinated between outpatient and inpatient providers. Dialysis patients are dependent on many medications to manage their care that are often administered at the dialysis facility, and which must be continued appropriately during transitions into and out of inpatient care and long-term care.  Long-term care settings that offer ongoing medical care, such as nursing homes and home health providers, must also track and communicate administration of medications during patient transitions.  Finally, ambulatory surgical centers frequently administer medications to patients, and in the case of medically complex patients, knowing what was administered and in what dose can frequently be necessary to avoid medication interactions and other negative events associated with medication. 

CMS-CCSQ Supports Medication Administration Patient for USCDI v6

Recommendation: CMS CCSQ recommends the Medication Administration Patient element be advanced to Level 2 and added to final USCDI v6.

Rationale: CMS CCSQ recommends inclusion of the Medication Administration Patient data element into USCDI v6 since this data element, and others related to medication administration, is important for medication reconciliation and continuity of care especially during transitions of care between acute and post-acute settings. The Medications data class lacks the necessary detail to effectively differentiate between active, ordered, or administered medications, which hampers accurate clinical evaluation and patient safety. Medication administration is a key priority for CMS and the Centers for Disease and Control Prevention (CDC) programs as its essential for quality improvement and public health surveillance. Adding the data element Medication Administration Patient to USCDI v6 will support a more comprehensive exchange of medication information. 

CMS-CCSQ Support Medication Administration Patient for USCDI v6

Data Element: Medication Administration Patient (Level 1)

1. Recommendation: Advance the Medication Administration Patient data element to Level 2 and add to Final USCDI v6.
2. Rationale: CMS recommends inclusion of the Medication Administration Patient data element into USCDI v6 since this data element, and others related to medication administration, is important for medication reconciliation and continuity of care especially during transitions of care between acute and post-acute settings. The Medications data class lacks the necessary detail to effectively differentiate between active, ordered, or administered medications, which hampers accurate clinical evaluation and patient safety. Medication administration is a key priority for CMS and the Centers for Disease and Control Prevention (CDC) programs as its essential for quality improvement and public health surveillance. Adding the data element Medication Administration Patient to USCDI v6 will support more comprehensive exchange of medication information.

PLEASE INCLUDE IN USCDI

• This MUST finally be included in USCDI.  Multiple agencies have made a STRONG case for this.  Continued lack of inclusion in USCDI is difficult to comprehend as at is a basic healthcare component used widely around the globe.  Additionally, relegation all the way to Level 0 contradicts all fact:

It is central to Medication Administration records and has been part of FHIR for years.  Represented by many FHIR IG's including Vulcan RWD IG (https://build.fhir.org/ig/HL7/vulcan-rwd/) , AU Base Medication Administration - AU Base Implementation Guide v4.2.2-ci-build (fhir.org), Home - Epic on FHIR, etc)

In the Vulcan RWD IG, the IG does not ask for very much, but it does expect Administered Medication to be standardized in HL7 FHIR.  The minimum the RWD IG requires is 

1. ... status        code    in-progress | not-done | on-hold | completed | entered-in-error | stopped | unknown
   ... medication[x]    CodeableConcept, Reference(Medication)    What was administered
   ... subject    S    1..1        Who received medication
   ... effective[x]    dateTime, Period    Start and end time of administration

Any in-patient healthcare facility contains administered medication data and is a critical aspect of healthcare information.  If not used by TEFCA, there will be zero knowledge of actual administered medications which will cause a needless risk to the health of the public.

Further, having this at Level 1 makes no sense: Level 2 at minimum is more accurate, and it used to be in Level 2.  And it really should be part of USCDI

Represented by a terminology standard or SDO-balloted technical specification or implementation guide.

Data element is captured, stored, or accessed in multiple production EHRs or other HIT modules from more than one developer.

Data element is electronically exchanged between more than two production EHRs or other HIT modules of different developers using available interoperability standards.

Use cases apply to most care settings or specialties.