Comments on ONC Test Data for Verify Opioid Treatment Plan Measure

Below are the comments I submitted to ONC regarding their proposed test data for the new opioid related measures introduced into the inpatient promoting interoperability program, specifically, the Verify Opioid Treatment Plan measure.

Clarification of Data Elements

Regarding the “Sought Signed Opioid Treatment Agreement” and “Signed Opioid Treatment Agreement Identified and Incorporated into CEHRT” test data options, I would suggest adding a test data note to clarify what each means and also changing the “No” value in the latter field to “Not Incorporated”.

To qualify for the numerator, the signed opioid treatment agreement (SOTA) has to be sought when the denominator scenario is met and then if identified, incorporated into the CEHRT. Here are the four basic scenarios regarding SOTA, impact on the numerator value, and brief commentary on why I understand this to be the case.

  • No SOTA sought - +0 in numerator. The whole point of the measure is to seek a SOTA so this obviously does not meet the measure intent.

  • SOTA sought but not received (or “not identified”) - +1 in numerator. In this case, a SOTA was sought, but it never received one from the patient or care team. This seems to be a scenario to not punish the provider due to lack of data despite best effort attempts.

  • SOTA sought and then identified but not incorporated into the CEHRT - +0 in numerator. In this case, there is a SOTA available but the provider has not incorporated it into the CEHRT per the measure instructions.

  • SOTA sought, identified, and incorporated into the CEHRT - +1 in numerator. This is the ideal case for this measure.

Assuming that is correct, the “not identified” option in the test data is more of an explicit checkbox/confirmation that no SOTA was received despite best effort attempts from the provider. I believe that should be stated within the test data notes to clarify intent. That will be important for developers as they design their system to support this measure. On the other hand, if these assumptions are wrong then I would suggest clarifying in the test data notes to better explain it.

Also, I would suggest changing the “no” in the SOTA identified and incorporated into CEHRT field to “not incorporated” to be more explicit of what is happening and note that in the test data notes.

Additional Test Scenario Option

I think the test data would benefit from one more additional scenario. I think a scenario where the SOTA is sought, identified, and incorporated into the CEHRT (meeting the numerator criteria) but without a 30-day duration of schedule II opioid prescriptions within the 6-month look back period (thus not meeting the denominator criteria) would be a good test. Something like this (NOTE - you have to click the image below to expand it and show all cells)…

This would result in a +0/+0 change in the denominator and numerator. While this may seem to be rather simple scenario, I believe it would be a good test for a few reasons. First, there is no scenario in the existing test data where a schedule II opioid prescription is generated and transmitted electronically but it fails the check of 30-day duration within the 6-month look back period. We should be testing both aspects of the denominator criteria. For that matter, it would be a good test of a 30-day duration that occurs beyond the 6-month lookback period to verify that activity does not cause the denominator to increase but that may be beyond the scope of this test data.

The other reason is that it could expose a potential issue in the measure logic implementation of a developer who “accidentally” increments the denominator whenever the numerator is met. This would help verify this is not done.

Finally, it alludes to the idea that a physician may still want a SOTA even if the opioid duration was less than 30 days. It is not necessarily a “bad” thing to have a SOTA anytime a patient has an opioid prescription.

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