Skip to end of metadata
Go to start of metadata
Status

APPROVED

e-Vote Close Date

 

Affirm-Negative-Abstain6-3-1
Date Approved

 

Work GroupPharmacy
Project Insight ID1654
Work Groups that submitted votes

Anesthesia

CBCP

CDS

Clinical Genomics

CQI

Emergency Care

LHS

Patient Care

Pharmacy

Public Health

Work Groups that did not submit votes

BR&R

CIC

Devices



  • For each Work Group, choose Affirmative, Negative, Abstain

  • If you are voting for a WG AND are also a co-chair for another WG in the CSD, please include a comment to indicate which WG you are voting on behalf of.

  • Use the  in the comments section to add comments to the vote.

  • Feel free to comment inline on Confluence documents*.

  • Negatives that do NOT have a comment will be considered abstain. Please register your vote below.

PSS: NHSN Inpatient Medication Administration Reports


Project Approval Request

Choices Your Vote Current Result: (10 Total Votes) Comments
abstain Project Approval Request
1 Votes , 10%
affirmative: Craig voting for Public Health
affirmative: Anesthesia
affirmative Project Approval Request
6 Votes , 60%
negative (with comment only) Project Approval Request
3 Votes , 30%



*  Refer to Can I add comments without editing the page? for directions.

11 Comments

  1. The ECWG is concerned the PSS does not reflect actual activity in the medication reporting space. The scope of this PSS is too limited to be of value to the general informatics community who is required to report medication administration events for research, reporting to registries, FDA reporting and reporting to local and state public health agencies.

    The statement that Medication Reconciliation lists are "too new" is inaccurate as every HITECH ONC certified EHR must be able to accommodate this functionality and is utilized hundreds of times a day by large health systems.

    All the members of PCORnet, OHDSI and the CTSA ACT network report inpatient mediation administration events in a structured fashion for their different information models. The use of other sources of medication information is well known to be inaccurate hence the extraction from the MAR of the actual event. These processes are already vendor neutral. 


    1. Response from Project Team: Paragraph 1

      Response: We thank Dr McClay for this point and appreciate that there are medication reporting activities other than the one proposed by this PSS. However, we are not aware of any reporting requirements or data streams to federal public health agencies that 1) are based on hospital eMAR data, 2) are fully electronic, 3) leverage FHIR resources, 4) report at the patient-level, and 5) are national in scope, as is intended with this PSS and for the NHSN use case.

      This PSS builds on long-standing experience with medication administration data collected by NHSN for the Antimicrobial Use and Resistance module, https://www.cdc.gov/nhsn/pdfs/pscmanual/11pscaurcurrent.pdf, expanding the use case to non-aggregated data streams, for medications other than antibiotics, and for hospitalized patients diagnosed with COVID-19, thus filling a key gap in our understanding of how medications were used for hospitalized patients during the pandemic and building a foundation for similar data collection in future public health use cases.

      Affirming the importance of this type of medication reporting activity, CDC, CMS, and several other entities recently publicly commented on the need to incorporate medication administration events into USCDI requirements: e.g., https://www.healthit.gov/isa/uscdi-data/medication-administration-dose and https://www.healthit.gov/isa/uscdi-data/medication-administration, reflecting the lack of medication reporting activities that are currently capable of leveraging eMAR data in this way and as outlined by this PSS.

      1. Thank you for the clarification. I appreciate the thoughtful comments.

    2. Response from Project Team: Paragraph 3

      We have previously worked with one of the PCORnet networks (CARPRiCORN) and published a study based on data from medication administration events: https://pubmed.ncbi.nlm.nih.gov/32833937/. Our experience suggests that normalizing the medication administration data across multiple centers and PCORnet networks to achieve data streams similarly to what is being suggested by this PSS would take considerable time, effort, and resources at each participating center beyond what can be achieved by establishing new guidance on how to report these data to a single system like NHSN. We appreciate the point regarding CTSA; however, this PSS addresses non-clinical trial contexts.

    3. Response from Project Team:  Paragraph 2

      Response: Thank you for this correction, we have modified this statement in the PSS to reflect that it is not the newness of medication reconciliation integration into EHRs per se, but rather the accuracy of "medication lists" that are generated from these activities when relied upon as the sole source of "truth" for medications administered in the hospital (Section 3b). There is an increasingly large body of literature that documents the challenges inherent to "med rec" workflows. Although deeply integrated into EHRs and clinical workflows, med rec workflows that are source of these medication lists remain disparately performed across U.S. hospitals yielding different information across medication lists (e.g., https://pubmed.ncbi.nlm.nih.gov/28434453/).

  2. voting negative for LHS and supporting Jim McClay's comment and assessment of gaps and deficiencies in the project proposal.  

    1. Response from Project Team:

      Response: We have addressed Dr McClay's comments above and are happy to provide additional information if there are any remaining concerns.

  3. Prefer to see responses to Jim McClay's comments to consider changing to affirmative. (voting for CQI). I think the ability to report a MedicationAdministration event is valuable but without specific examples as to why such events would be reportable to the NHSN the proposal suggests that it might cover all administration events. I suspect the intent is to request administration events only when a potential adverse event has occurred subsequent to that administration. Clarifying the use case would be very helpful. And it will help to clarify if the intent is for clinician-administered medications (I.e., not self-administered) and whether the scope includes inpatient, outpatient (e.g., Emergency Department, Short-stay Surgicenters) and specific office visits during which medication administration occurs.

    1. Response from Project Team: Sentence 1

      Response: We have addressed Dr McClay's comments above and are happy to provide additional information if there are any remaining concerns.

      Response from Project Team: Sentence 2

      Response: Thank you. We have added a clarification in the PSS to reflect the intent is to capture all medication administration events, not just those linked to adverse events (Section 3a). This is an example of how we worked with CDC during the COVID-19 public health response to characterize medication exposures and a similar use case:https://jamanetwork.com/journals/jamainternalmedicine/article-abstract/2767895. These data were for outpatient settings and identified >1000% increase between October 2019 and February 2020 in pharmacy dispensing of the combination of hydroxychloroquine and azithromycin, a drug-drug combination with potential for life-threatening adverse drug events. We were challenged in identifying similar data for inpatient (hospital) settings that could be gathered in an efficient, timely, and nearly nationally representative fashion. This was especially important as there was uncertainty, fluidity, and scarcity in medications and recommendations for pharmacologic treatments throughout the pandemic. For example, after the Emergency Use Authorization for hydroxychloroquine use in hospitalized patients with COVID-19 was revoked by the FDA during the pandemic, https://www.fda.gov/drugs/drug-safety-and-availability/fda-cautions-against-use-hydroxychloroquine-or-chloroquine-covid-19-outside-hospital-setting-or, it would have been important to have baseline and ongoing trends regarding hospital medication administration events to assess adherence to these recommendations.

      Response from Project Team: Sentence 5

      Response: Thank you. We have added a clarification in the PSS (Section 3a) to reflect the intent is to capture clinician-administered events only in inpatient settings (for example, as defined by the NHSN "FacWideIN" variable). This excludes: emergency department, observation/short stay, inpatient rehabilitation, outpatient surgical centers, and other outpatient (including physician office) settings.

  4. No feedback to project team responses received from other WGs by end of day December 9th.  Forwarding to the TSC for approval.