Pharmacologic agents used in the diagnosis, cure, mitigation, treatment, or prevention of disease.

Data Element

Medication Administered Code
Description

A code (or set of codes) that specify the medication that was administered.

Comment

Medication Administered Code - CSTE Comment

Medication data are critical for exchange with public health and is included in eCR standards. They are particularly important for STI programs, HIV and TB surveillance, as well as for public health response and surveillance for antimicrobial resistant pathogen infections. The ability to exchange data on prescribing of opioid medications in particular is of great importance to public health programs which aim to reduce opioid overdoses and deaths.

CDC's support for CMS comment for USCDI v7

CDC supports CMS CCSQ recommendation for Date Medication Administered (Level 0), Medication Administered Code (Level 0), Medication Administration Dose (Level 0), and Medication Administered Reason Reference (Level 0) these elements be advanced to Level 2 and added to final USCDI v7.

CMS-CCSQ Supports Medication Administered Code for USCDI v7

Recommendation:  CMS CCSQ recommends Date Medication Administered, Medication Administered Code, Medication Administration Dose, and Medication Administered Reason Reference be advanced to Level 2 and added to final USCDI v7.

Rationale:  CMS CCSQ, CDC, and the Council of State and Territorial Epidemiologists (CSTE) requests the inclusion of the Date Medication Administered (Level 0), Medication Administered Code (Level 0), Medication Administration Dose (Level 0), and Medication Administered Reason Reference (Level 0) data elements in USCDI to fill critical gaps in patient safety and care quality. Medication Administration data elements are also supported by RxNorm and are currently collected and exchanged by at least one national EHR vendor. 

Medication administration remains a key priority for CMS and CDC programs as it is essential for quality improvement and public health surveillance. Moving these data elements to USCDI v7 would support access to critical information to care providers. These data elements are important for medication reconciliation and continuity of care, especially during transitions of care between acute and post-acute settings. Existing Medications class data elements in USCDI record when a medication has been ordered or dispensed, but they do not reflect the data associated with the actual administration of the medication to the patient. These medication administration data elements are critical for providing this clarification. Including Medication Administration data elements in USCDI v7 would also facilitate documentation and use of medication related data already being collected in health care settings, including on the Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI) (CMS IRF-PAI Manual Version 42; Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI) and IRF-PAI Manual), the Minimum Data Set (MDS) (Long-Term Care Facility (LTCF) Resident Assessment Instrument (RAI) 3.0 User Manual Version 1.19.1MDS 3.0 RAI Manual), OASIS (OASIS User Manuals), and Long-Term Care Hospital (LTCH) Continuity Assessment Record and Evaluation (CARE) (LTCH CARE Data Set (LCDS) & LCDS Manual). Additionally, as shown in this crosswalk of QI-Core, US Core and FHIR resources, there is currently a gap in US Core with the exclusion of Medication Administration data elements which could be addressed by their inclusion in USCDI v7

Several technical and practical considerations also support this recommendation:

  1. The Medication Administered Code data element is represented in both the PACIO Standard Medication Profile (SMP) IG and the Vulcan Real World Data (RWD) IG. It can be captured, stored, and exchanged electronically in all EHRs, supporting use cases like prior authorization application programming interfaces (APIs) and provider-payer APIs. This data element applies across all healthcare settings and diagnoses.
  2. The Medication Administered Dose data element is similarly represented in the PACIO SMP IG and the HL7 Clinical Document Architecture (CDA) IG.

Applicable standards: 

  1. Date Medication Prescribed and Date Medication Administered: dateTime Data Type (FHIR; 2.1.28.0 Datatypes).
  2. Time Medication Prescribed Code and Medication Administered Code: RxNorm (National Library of Medicine (NLM) Unified Medical Language System (UMLS) RxNorm).
  3. Medication Prescribed Dose Units and Medication Administration Dose Units: Unified Code for Units of Measure (UCUM).

Together, these data elements fill essential gaps in medication reconciliation, facilitate smoother care transitions, and contribute to better patient outcomes through improved medication administration tracking and coordination across care settings.

CMS-CCSQ Supports Medication Administered Code for USCDI v6

Recommendation: CMS CCSQ recommends the Date Medication Administered, Medication Administered Code, Medication Administration Dose, and Medication Administered Reason Reference data elements be advanced to Level 2 and added to final USCDI v6.

Rationale: CMS CCSQ, CDC, and the Council of State and Territorial Epidemiologists (CSTE) requests the inclusion of the Date Medication Administered (Level 0), Medication Administered Code (Level 0), Medication Administration Dose (Level 0), and Medication Administered Reason Reference (Level 0) data elements in USCDI to fill critical gaps in patient safety and care quality. Medication administration remains a key priority for CMS and CDC programs as it’s essential for quality improvement and public health surveillance. Moving these data elements to USCDI v6 would support access to critical information to care providers. These data elements are important for medication reconciliation and continuity of care especially during transitions of care between acute and post-acute settings. Existing Medications Class data elements in USCDI record when a medication has been ordered or dispensed, but they do not reflect the data associated with the actual administration of the medication to the patient. These medication administration data elements are critical for providing this clarification. They are also supported by RxNorm. Including Medication Administration data elements in USCDI v6 would also facilitate documentation and use of medication related data already being collected in health care settings, including on the Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI) (CMS IRF-PAI Manual Version 42; Inpatient Rehabilitation Facility Patient Assessment Instrument (IRF-PAI) and IRF-PAI Manual), the Minimum Data Set (MDS) (Long-Term Care Facility (LTCF) Resident Assessment Instrument (RAI) 3.0 User Manual Version 1.19.1MDS 3.0 RAI Manual), OASIS (OASIS User Manuals), and Long-Term Care Hospital (LTCH) Continuity Assessment Record and Evaluation (CARE) (LTCH CARE Data Set (LCDS) & LCDS Manual).

Several technical and practical considerations also support this recommendation:

    i. The Medication Administered Code data element is represented in both the PACIO Standard Medication Profile (SMP) IG and the Vulcan Real World Data (RWD) IG. It can be captured, stored, and exchanged electronically in all EHRs, supporting use cases like prior authorization application programming interfaces (APIs) and provider-payer APIs. This data element applies across all healthcare settings and diagnoses.

    ii. The Medication Administered Dose data element is similarly represented in the PACIO SMP IG and the HL7 Clinical Document Architecture (CDA) IG.

Applicable standards: 

    i. Date Medication Prescribed and Date Medication Administered: dateTime Data Type

    ii. Time Medication Prescribed Code and Medication Administered Code: RxNorm

    iii. Medication Prescribed Dose Units and Medication Administration Dose Units: Unified Code for Units of Measure

Together, these data elements fill essential gaps in medication reconciliation, facilitate smoother care transitions, and contribute to better patient outcomes through improved medication administration tracking and coordination across care settings.

CSTE Comment - v6

CSTE supports inclusion of this data element in USCDI V6. Please see previously submitted CSTE comments for additional recommendations.

This must be included 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:
  •  
  • Not represented by a terminology standard or SDO-balloted technical specification or implementation guide:  FALSE: 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 
  • ... 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
  • Data element is captured, stored, or accessed in limited settings such as a pilot or proof of concept demonstration: FALSE: 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.
  • Data element is electronically exchanged in limited environments, such as connectathons or pilots: FALSE: 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.
  • Use cases apply to a limited number of care settings or specialties, or data element represents a specialization of other, more general data elements: FALSE: 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.
  •  
  •  
  • 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.

CSTE Comment - v5

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.   CSTE also strongly agrees that the ability to exchange data on prescribing of opioid medications in particular is of great importance to public health programs which aim to reduce opioid overdoses and deaths.

CDC's Comment for draft USCDI v5

CDC-CMS Joint Priority Data Element. 

See letter here (submitted on 1/29/2024): https://www.healthit.gov/isa/sites/isa/files/2024-02/FINAL_CDC%20and%20CMS-CCSQ%20Joint%20USCDI%20v5%20submission%20letter_012924.pdf

CDC and CMS-CCSQ Joint Support for Medication Admin. Code

Thank you for opportunity to comment on this data element. The Centers for Medicare and Medicaid Services (CMS) and the Centers for Disease Control and Prevention (CDC) emphasize the importance of patient safety being reflected in the USCDI standards. As an integral aspect of patient safety, medication management is critical to patient care and coordination between providers, and related quality and public health enterprises. Medication administration, specifically, is a critical concept for CMS and CDC programs that support quality improvement and public health surveillance. We continue to emphasize the need for greater specificity in the USCDI Medications data class. The medications data class in USCDI is currently inadequate to support patient safety, quality improvement, or public health. The medication data elements do not differentiate among medications that are active, ordered, and 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 and promote patient safety. CMS and CDC strongly recommend the Medication Administration (Level 2)/Medication Administered Code (Level 0) in the Medications data class be added to USCDI.

CDC's comment on behalf of CSTE for USCDI v5

  • CSTE strongly 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.   CSTE also strongly agrees that the ability to exchange data on prescribing of opioid medications in particular is of great importance to public health programs which aim to reduce opioid overdoses and deaths.

Log in or register to post comments

Add a New Comment

Review comment and Submit

Edit
Comment #1
PDF, Doc, Docx
Max Size : 10 MB