What does CMS consider a high risk medication for the elderly?

December 5th, 2013 by Rod Baird

Perhaps there is a simpler answer than “it depends.” Until this fall, my awareness of this issue was vague at best. We knew that this was one of the concepts embedded in the 2014 EHR Quality Measures, but nothing more.

My awareness was raised when one of the LTC physician groups I work with received their 2012 Value Based Purchasing QRUR Report, which included this as a “Quality Measure.” The report showed the group had a higher use of problematic medications when compared to all ambulatory practices. (Note to regulators: Only one of four LTC groups we work with had this measure.)

Our EHR company is deeply immersed in passing the second wave of 2014 Meaningful Use testing, which included testing eCQMs (electronic clinical quality measures). One of my roles is devising a recommended Quality Strategy for our customer LTC groups to implement, so selecting eCQMs that “work” in LTPAC is critical. That led to dissecting the guts of many measures to analyze how they’d affect real-life physicians working in nursing homes.

Here is the list of High Risk Medications associated with Ambulatory EHR eCQM #156.

All well and good, but I’ve learned to double check on what CMS says. A quick web search proved that wisdom – CMS uses a different list of High Risk Medications to drive the Group Practice QRUR reports.  We haven’t had time to do a cross comparison, but a quick search identified some major differences.  The list for eCQM #156 included Morphine Sulphate-30mg extended release tablets, a common medication for pain management in hospice. This med isn’t on the GPRO list. The list lengths are radically different, but one uses RxNorm codes (which are types of drugs) and the other NDC Codes (which contain more specific identifying info), so there may be more correlation than it first appears.

Looking at these lists, regardless of which to follow or the wisdom of inclusion/exclusion of any particular medication, begs the question: How does the typical PCP working in a LTC setting manage to comply? How does the typical EHR or ePrescribing vendor alert physicians about the relation of a medication to these lists?

There is no issue with the need to reduce the use of polypharmacy and certain medications in our LTC population, but shouldn’t there also be a recommended strategy for accomplishing this objective? If anyone wonders why there is so much physician and provider burnout, you don’t have to look very far for some smoking guns.

Rod Baird

About Rod Baird

Rod Baird is the Founder and President of Geriatric Practice Management (GPM). Since 1977, he’s led provider and management organizations that deliver care to Medicare/Medicaid beneficiaries. Past programs he’s overseen include home health, personal care, hospice, rehabilitation hospitals, adult and psych daycare, alcohol/drug rehabilitation, industrial medicine and primary care practices. The Centers for Medicare and Medicaid Services (CMS) selected Baird as one of only 73 individuals to serve with its InnovationProgram. His educational background includes a Master’s Degree in Physical Chemistry from the American University, Washington, D.C.

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