Medications

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.