Summary
CMS506FHIR's discharge prescribing indicator should not be interpreted as an absolute clinical prohibition on every concurrent opioid/benzodiazepine prescription.
Detail
Reviewed on 2026-11-03. The pinned CQL uses inpatient encounters with an opioid or benzodiazepine at discharge. Its numerator identifies two or more distinct opioid medications, or an opioid and benzodiazepine. The exclusion definition includes cancer-related pain, sickle cell disease, palliative/hospice interventions, qualifying opioid-use-disorder treatment, and specified discharge dispositions, with explicit timing and data requirements. Merely having one of these clinical circumstances is not proof that the encoded exclusion has been satisfied.
The CDC 2022 opioid prescribing guideline, published November 4, 2022, addresses outpatient pain prescribing and excludes sickle-cell-related pain, cancer-related pain, palliative care, and end-of-life care from its scope. Recommendation 11 advises particular caution and an individual benefit–risk assessment for concurrent opioid/benzodiazepine use. It also states that buprenorphine or methadone for opioid use disorder should not be withheld solely because a patient takes benzodiazepines or other CNS depressants. These are clinical guidance statements, not replacements for the measure's discharge numerator or exclusions.
Resolution
Open for clinical and measure-steward review. Explain a numerator result in the context of the discharge measure and its encoded exclusions; avoid using it alone to prescribe abrupt discontinuation or denial of opioid-use-disorder treatment. Proposed implementation tests should distinguish two-opioid and opioid/benzodiazepine branches and verify exclusion timing. No such tests have been executed for this note.