Medications

CDC comment on MedicationAdministration Resource

MedicationAdministration Resource

• MedicationAdministration describes the event of a patient consuming or otherwise being administered a medication. This may be as simple as swallowing a tablet or it may be a long running infusion. Related resources tie this event to the authorizing prescription, and the specific encounter between patient and health care practitioner as defined here in Section 11.2 of HL7 FHIR Release 4: https://hl7.org/fhir/R4/medicationadministration.html. 
• Examples can be found here: https://hl7.org/fhir/R4/medicationadministration-examples.html.  
• Usage notes: The scope of this resource covers the recording of medications and vaccine administrations that are oral, injected, intra-venous within care settings.  This includes self-administered medications. This concept is distinct from medication orders, dispensations, and procedures and, to the best of our knowledge and experience with real-world FHIR data, this concept is not currently represented by any other FHIR resource or data element. For additional details, please see Section 11.2.1 of HL7 FHIR Release 4: https://hl7.org/fhir/R4/medicationadministration.html. 
• Applicable standard: FHIR v4.0.1 https://hl7.org/fhir/R4/index.html  

Narrative or Evidence for inclusion in USCDI v6

In a prior ONC evaluation, MedicationAdministration was evaluated as “applying to a limited number of care settings or specialties, or data element represents a specialization of other, more general data elements”. Additionally, MedicationAdministration was deemed as a specialized use or subset of an existing USCDI v4 data element Performance Time in the Procedures data class of USCDI v4.  

Current medication and procedure concepts in USCDI are incomplete representations of medication administration. Alternate FHIR medication data elements do not capture: 

• Whether the patient actually received the medication. This is fundamentally different than “ordered” medication in MedicationRequest resource, https://hl7.org/fhir/r4/medicationrequest-definitions.html#MedicationRequest. 
• The final dose of the administered medication. This is fundamentally different than the “amount” of the medication in the Medication resource, https://hl7.org/fhir/r4/medication-definitions.html. 
• The route of administration of the medication. This is fundamentally different than “dose form” of the medication in the Medication resource, https://hl7.org/fhir/r4/medication-definitions.html#Medication.form. 

“Procedure” resource, https://hl7.org/fhir/r4/procedure.html, cannot be relied upon as a representation of medication administration as this does not reflect the reality of the EHR clinical workflow in U.S. hospitals—i.e., “medication” instances are not intended to be captured under “procedure” concepts. In CDC/NHSN’s current use of real-world FHIR data, we have not yet found any evidence that medication administration instances can be reliably identified based on Performance Time in the Procedures data. 

“Medication” resource, https://hl7.org/fhir/r4/medication.html, specifies the actual medication, but it does not differentiate between medication requests (i.e., orders), medication administrations, and medication dispense activities, and it does not provide information about when the medication was ordered, dispensed, or administered to the patient.   

“MedicationRequest” resource, https://hl7.org/fhir/R4/medicationrequest.html, represents medication orders/prescriptions. Published evidence demonstrates that orders/prescriptions are not accurate or sufficient representations of the medication ultimately received by the patient.1 A medication request represents a clinician’s order or a prescription. It is distinctly separate from administration activities, as the medication administered can have differences from the order. This occurs because medication orders can be changed, cancelled, or never administered, thus orders do not reflect actual medication exposure. 

MedicationAdministration is a required resource for reporting of FHIR digital quality measures (dQMs) to CDC/NHSN. The CDC/NHSN dQMs that require MedicationAdministration will adhere to the reporting framework requirements in the balloted HL7 NHSN dQM Reporting Implementation guide (IG), https://hl7.org/fhir/us/nhsn-dqm/2024SEP/index.html. CDC’s National Healthcare Safety Network has balloted an HL7 that defines the framework for reporting FHIR dQMs. The CDC/NHSN dQM Content IG that will follow this IG points to specific use cases where MedicationAdministration is a required resource to support national public health surveillance and patient safety efforts. This HL7 NHSN dQM Reporting IG was tested during the May 24, 2024, HL7 FHIR Connectathon and Working Group Meeting: https://confluence.hl7.org/display/FHIR/2024+-+05+NHSN+dQM+Reporting. Selected data elements within the MedicationAdministration resource will be “required” or “must support” as part of requirements to report digital quality measures to CDC/NHSN: https://www.cdc.gov/nhsn/fhirportal/about.html.   

MedicationAdministration is in now required as part of real-world implementation use cases across U.S. hospitals and being requested for national public health surveillance use cases from different EHR vendors (e.g., Epic, Oracle/Cerner, Altera, Meditech).  NHSN and U.S. hospitals are currently undertaking Production (real-world) implementations of FHIR digital quality measures for which this Resource is required to calculate patient safety metrics, including healthcare-associated infections and adverse drug events, and to support pandemic preparedness as described here: https://www.cdc.gov/nhsn/nhsncolab/index.html: https://academic.oup.com/jamia/advance-article/doi/10.1093/jamia/ocae064/7639052.  While we know of one EHR vendor voluntarily supporting exposing the MedicationAdministration resource and able to successfully exchange these data with NHSN, other vendors do not. This creates a disparity among U.S. hospitals in data reporting and does not allow for accurate national enumeration and benchmarking of patient safety events. The MedicationAdministration resource is required for data exchange for numerous use cases across Department of Health Human Services agencies, including CDC, CMS, and FDA: 

 https://hl7.org/fhir/us/nhsn-dqm/2024SEP/index.html. 

 https://build.fhir.org/ig/HL7/fhir-icsr-ae-reporting/branches/main/index.html  

 CDC requires MedicationAdministration data as part of reporting FHIR digital quality measures (dQMs) to CDC/NHSN. NHSN FHIR dQMs currently utilize the US Core 3.1.1 standard, which, along with all current US Core versions, does not include MedicationAdministration. In addition to US Core, NHSN dQMs leverage the MedicationAdministration profile requirements defined in HL7 quality measure standards, including Da Vinci DEQM 3.1.0: https://hl7.org/fhir/us/davinci-deqm/STU3.1/ and QI Core 4.1.1:  https://hl7.org/fhir/us/qicore/STU4.1.1/ to evaluate data.

Medication exposure happens across the full spectrum of U.S. healthcare—ambulatory care, acute care, long-term care, surgical care, and numerous other healthcare settings. The importance of enumerating medication exposure across outpatient and inpatient settings was well-highlighted during the 2020 COVID-19 pandemic, during which challenges emerged in reporting of COVID-19 medication data to state and federal public health agencies limited our understanding and mitigation of the pandemic. Additionally, the lack of medication administration data presents a substantial challenge to CDC and jurisdictions in responding to healthcare-related outbreaks, where improper use of medications is often implicated in multi-state outbreaks.

CMS-CCSQ Support for Medication data elements for USCDI v6

Data Elements: Medication Administered Code, Medication Administration Dose, and Medication Administered Reason Reference (Level 0)

1. Recommendation: Advance the Medication Administered Code, Medication Administration Dose, and Medication Administered Reason Reference data elements to Level 2 and add to Final USCDI v6.
2. Rationale: CMS requests the inclusion of the Medication Administered Code, Medication Administration Dose, and Medication Administered Reason Reference data elements in USCDI v6 to fill critical gaps in patient safety and care quality. These data elements are important for medication reconciliation and continuity of care especially during transitions of care between acute and post-acute settings. They are also supported by RxNorm. Medication administration continues to remain a key priority for CMS and CDC programs as its essential for quality improvement and public health surveillance.

Medication Administration FHIR Resource and US Core

CDISC supports the use of the MedicationAdministration Resource as part of US Core IG Medication Profile.  

We recommend the ONC and USCDI promote the use of FHIR MedicationAdministration Resource elements to support the HL7 US Core to use case. This will aid in the full picture of the medication perspective. The current US Core has Medication, MedicationDispense,and MedicationRequest. Currently, the US Core which is informed by USCDI does not include the MedicationAdministration Resource.

This will help researchers understand all aspects of the medication: the request (order), the dispense (pharmacy filling), the statement (patient/participant stating meds taken) and finally, the most important in healthcare - the medication administration (the health providers giving the drugs to the patients).

The record of medication administration is a central healthcare use case. It represents the record where a healthcare provider has administered the drug. This data not only helps with clinical research but will provide insight into drugs ordered (MedicationRequest), drugs dispensed (MedicationDispense) by having the ability to see in the hospital/healthcare setting which drugs were actually administered against those ordered and provided which makes a difference in the analysis of how sick a patient is. For example, the Levophed was ordered and given is very different than the Levophed was on standby for hypotension.  Consider as well, the use of MedicationStatement which means the patient said they were taking these medications. This likely is the most accurate reflection of what the person is actually taking. This can be validated against the MedicationRequest and MedicationDispense which provides insight on if indeed the person is taking the medications and if they are taking them as often as prescribed.

The key aspect of capturing med records distinctly include collecting all core bits of information regarding the records of medications and their administration should be a part of the US Core. 

In the current US Core FHIR build, R6.
MedicationAdministration is Maturity Level 2; MedicationDispense is Maturity Level 2; MedicationRequest is Maturity Level 4; MedicationStatement is Maturity Level 4; Medication is Maturity Level 4

The Medication Administration resource is used in the following IGs:

• HL7 Vulcan Retrieval of Real World Data for Clinical Research
• HL7 FHIR to CDISC Joint Mapping Implementation Guide
• CDISC side - FHIR to CDISC Joint Mapping Implementation Guide (published simultaneously in a joint effort to bridge clinical research across the two communities, healthcare and research)

This fulfills the following criteria for promotion:

• Criterion #1 - Maturity - Current standards: Level 2 - Data element is represented by a terminology standard or SDO-balloted technical specification or implementation guide.
• Criterion #2 - Maturity - Current Use: Level 1 - Data element is captured, stored, or accessed in at least one production EHR or HIT module.
• Criterion #3 - Maturity - Current Exchange: Level 1 - Data element is electronically exchanged between two production EHRs or other HIT modules using available interoperability standards.
• Criterion #4 - Use Case(s) - Breadth of Applicability - Level 1 - Use cases apply to several care settings or specialties.
   
• Further rationale:

•    The record of an actual administration of a medication to a patient is one of the most central healthcare use cases.  Currently a suite of Medication administration-related concepts are in the Level 2 section of USCDI.   All of these are central healthcare components so the longer the data for these concepts remain wildly unstandardized in US EHRs, the longer there will be no realistic expectation of interoperability. There are many strong justifications for need of standardized structured data of this concept the clinical research: 
•    These elements are not niche needs for a few research requirements.  They are the center of patient-provider data exchange and the continued lack of standardized representation of these concepts should be the single driving reason for their inclusion in USCDI version 5.
•    Healthcare use case: The lack of any standardized representation of administration of medications inherently prevents interoperability of this information and restricts critical sharing of this information across health systems (such us in those qHINs participating in TEFCA).  Lack of easy sharing of administered drugs can result in serious, sometimes lethal, misjudgments on patient medication usage.
•    A Clinical research context: Retrospective analyses of healthcare data are becoming a more common tool in clinical research for safety or efficacy for new indications of existing medications. In such analyses there may be one or more “exposure” drugs (ie, the drug of interest) and one or many “concomitant” medications. Researchers (and regulatory reviewers) will need to know enough information of the status of a drug administration where applicable. This information will supply critical differential information with which a researcher or regulatory reviewer can assess the relative probability of the listed drug record actually resulting in consumption by the patient. They can then determine the utility of the information in the context of the specific research and evidence generation needs of any given clinical study.

Medications Data Class - L2 Data Elements as of 9.20.2023

• Emory Healthcare (EHC) submits its support for the inclusion of all Data Elements currently listed as Level 2 under the Medications data class in draft USCDI v5.
• EHC submits its particular interest in the inclusion of Date Medication Prescribed and Date Medication Administered in Draft USCDI v5. EHC providers and quality officers use the time from prescription to delivery as a factor that can be reviewed to support responsive patient care. Longer periods of time can be indicators of more systemic problems – from workflow to SDOH-related patient experiences. If a framework for collecting these data elements were consistently available across the healthcare ecosystem, EHC and others would be better able to identify opportunities to improve care quality, provide patient support and/or implement new best practices, especially if available in concert with Negation Rationale and statuses. The applicable Fast Health Care Interoperability Resources (FHIR®) data type referenced in the data element submission supports a level of specificity, referencing both date and time, that would assist with care quality improvement activities.
• However, EHC encourages ONC to evaluate the benefit of having data elements that support the distinction of medication administration (i.e., given in an inpatient setting) and dispensation (i.e., given in an outpatient setting). Emory Healthcare offers for consideration “Date Medication Administered” and “Date Medication Dispensed,” which would mirror the Date Medication Administered Level 2 data element, but support a better understanding of the care context.

Comment

Recommend adding Medication Start Date and Medication End Date as data elements. This will ensure patient safety during medication administration and support the future of FHIR resources.

CMS/CDC v4 Priority: Medication Admin. Route and Date and Time

Management of medications is critical to patient care and coordination between providers, as well as related quality and public health enterprises. The current concept of medications in USCDI does not differentiate among medications that are active, ordered, and actually 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.

• We recommend the following elements be added regarding medications:
  • Medications Prescribed
  • Medications Administration/Medication Administered Code
  • Discharge Medications
  • Medication Administration Route
  • Medication Administration Dose
  • Medication Administration Date and Time

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.

The highlighted additional data elements 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.

NCPDP Comment

For all of data elements under Medication data class in Level 2, NCPDP recommends a review and restructure because it currently creates confusion and potential duplication.

Medication Administration Date/Time and Route

Consider adding data elements for:

• Date/Time of Medication Administration
• Route of Medication Administration

This comment is submitted on behalf of the National Emergency Medical Services Information System (NEMSIS) Technical Assistance Center.

Level 2 data element to USCDI v3

Vizient recommends adding the below Level 2 data elements to USCDI v3 to the Medications class. In support of these additions, use cases are also provided for consideration:

o Medication Administration: This allows for further insight and analyses of which medications were administered within visits.
o Negation Rationale: This will allow for analyses as to what medication orders are being placed and then subsequently cancelled on a regular basis in addition to why they are being cancelled.
o Dosage: This information allows for sharing of detailed dose information to patients and other parties rather than simple medication name which can lead to additional insights on dosing patterns.
o Discharge Medications: This distinguishes which medications were prescribed for a patient to start/continue from the point of discharge and minimize confusion with medications prescribed as an inpatient.
o Medications Dispensed: The allows for differentiation of which ordered medications were actually dispensed (e.g., generic). This may be different from what was ordered or administered as it is the result of a pharmacy system responding to a medication order.

Lantana Consulting Group Comment

The details of prescribing, dispensing, and administering medications are essential to patient care, care coordination, and quality measurement. Adverse drug events and opioid use/misuse is difficult to properly evaluate without the specifics of when a medication was administered or prescribed.  

Relying on Medication Request as the only USCDI medication data element limits the representation of medication exposure in healthcare data in the U.S and provides a distorted and inaccurate picture of the medication workflows in the healthcare system. A medication request is the clinician’s prescription but is a separate event from dispensing and administering the medication. A different medication may be dispensed or administered. 

We support data elements for full range of medication events to support public health, regulatory, research, and pandemic response. Lantana recommends the following elements for inclusion in USCDI V3:

• Medication Administration

• Code
• Performer
• Reason Reference
• Date/DateTime

• Medication Prescribed
  • Code
  • Date
  • Reason Reference

• Medication Dispensed
• Discharge Medications (Medication Request)
• Dosage
• Dosage/Route
  • Administered Dose
  • Administered Dose Units
  • Prescribed Dose
  • Prescribed Dose Units
  • Negation Rationale

The current Medication data elements specify the actual medication but does not differentiate medication order, medication administrations, and medication dispensing activities. It also does not provide information about when the medication was ordered, dispensed, and administered to the patient.

The current MedicationRequest profile should emphasize that it represents requests or orders. The MedicationAdministration profile which would represent medications received at the hospital remains at USCDI Level 2 which impedes accurate medication data collection.