Medications

CMS/CDC Joint USCDIv4 Priority: Medication Administered Code

CMS urges adding more specificity to the USCDI Medications Data Class as interoperability of medication information and management of medications is critical to patient care and coordination between providers, as well as related quality and public health enterprises—we continue to support the concept of a USCDI Task Force to appropriately specify and advance this important data class. 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. Specifically, these medication data elements are necessary for understanding adverse drug events, opioid use and misuse, and medication access.

The current concept of medications in USCDI does not differentiate among medications that are active, ordered, and actually administered/dispensed to the patient. Given these complexities, more clarity and structure are necessary in this data class to accurately evaluate and provide clinical care. These detailed medication data were also previously identified as a joint CMS-CDC priority area as they are used extensively in quality measurement and public health —for example, to monitor and respond to antibiotic prescribing patterns that facilitate the emergence of drug-resistant pathogens, but also exposes patients to needless risk for adverse effects. They are also routinely exchanged when prior authorization is required.

Maturity: These elements are classified as Level 2 by ONC and continues to have strong standardization and be in wide use.

• Current standards:
  • In FHIR US Core, there is a distinction between "Medication" and "Medication Request”; base FHIR and FHIR Quality Improvement (QI) Core IG includes "Medication Administration" and “Medication Request” profiles.
  • Within Medication Request, the ‘category’ is used to define discharge medications.
• Current uses, exchange, and use cases: Medication data are routinely captured in electronic health record (EHR) systems used by hospitals, providers, and other healthcare stakeholders, including pharmacies, and are routinely exchanged across providers and payers. Medication data are used extensively in CMS quality measurement and public health for surveilling national trends. Additionally, when prior authorization is necessary for a medication, details related to the medication (e.g., why the medication is given, the quantity needed) are exchanged to support the approval process. As noted in the ISWG recommendations report for USCDI v3, many medication data elements are already required for Health Information Technology (IT) Certification via other standards (National Council for Prescription Drug Programs [NCPDP] SCRIPT, Consolidated Clinical Document Architecture [C-CDA]) and are therefore already routinely exchanged, posing little additional burden by adding them to the USCDI.

CDC's comment on behalf of CSTE for USCDI v4

CSTE agrees with CDC. 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.

CDC-CMS Joint Priority Data Element for USCDI v4

CDC strongly supports inclusion of this element in USCDI v4.

Also, please add the following use case:

• Birth reporting use case: Healthcare facilities are required to report to state vital records offices if antibiotics were administered under two circumstances: 1) for the mom during labor and delivery and 2) for the newborn for suspected neonatal sepsis.  At the point of clinical care these elements identify suspected neonatal sepsis of the newborn and if the mother received antibiotics during labor.  These medications must be properly identify, and if they were administered in order to complete facility worksheets and birth certification.  It is required to report the administration of these medications to the State VROs electronic birth registration systems (EBRS), and to the National Vital Statistics System (NVSS).  This medical information is collected within the Facility Worksheet for the Live Birth Certificate (cdc.gov), and reported within the US Standard Certificate of Live Birth for national level reporting.  At the population level the state VROs and the NVSS provide aggregate data on births and risk factors that may impact the mother or newborn during labor and delivery and throughout life.

This element is also shared priority for both CDC and CMS as outlined in the joint support letter

CDC's Consolidated Comment

• Collected as part of antiretroviral history for routine HIV surveillance.
• 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/
• Important for National Healthcare Safety Network (NHSN) measures, including hypoglycemia and Clostridioides difficile (C Diff).
• Additional Technical Specifications: HL7 FHIR Health Care Surveys Content Implementation Guide (http://hl7.org/fhir/us/health-care-surveys-reporting/2022Jan/); HL7 FHIR Central Cancer Registry Reporting Content Implementation Guide (http://hl7.org/fhir/us/central-cancer-registry-reporting/2022Jan/).

CSTE Comment:

• 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.

This data element is CDC-CMS shared priority

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
   
• 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)