Medication Safety by
CIMRO of Nebraska Kansas Foundation for Medical Care
Quality Health Associates of North Dakota South Dakota Foundation for Medical Care
January 24, 2017
Welcome and Reminders
Welcome! Q & As at end of presentations Slides and recording will be available on the GPQIN website: Calendar > Past Events http://greatplainsqin.org
*2 to mute your line; *2 to unmute Utilize chat for questions and sharing
2
http:http://greatplainsqin.org
Medication Safety
3
Source: National Action Plan for Adverse Drug Event Prevention
Medication Safety
Admissions per 1,000 HRM Consumers 900.00
800.00
700.00
600.00
500.00
400.00
300.00
200.00
100.00
0.00 Overall FFS Diabetic Agents Opioids Anticoagulants
Readmissions per 1,000 HRM Consumers 200.00
180.00
160.00
140.00
KS KS120.00
NE NE 100.00
ND ND
SDSD 80.00
Nation Nation 60.00
40.00
20.00
0.00 Overall FFS Diabetic Agents Opioids Anticoagulants
Source: QIN‐QIO National Coordinating Center based on 2014 Medicare Part A & D claims
4
Any Diagnosis Code Principal Diagnosis Code
50
Medication Safety
300
Probable ADE Rate Probable ADE Rate
45
40 250
ADE Ra
te per
1,000
HRM
Con
sumers
ADE Ra
te per
1,000
HRM
Con
sumers
5
0 Anticoagulants Diabetic Agents Opioids
KS NE ND SD Nation KS NE ND SD Nation
35
30
25
Anticoagulants Diabetic Agents Opioids
200
150
100
20
15
10
Source: QIN‐QIO National Coordinating Center based on 2013 Medicare Part A & D claims
5
0
Medication Safety and Care Coordination
Source: National Action Plan for Adverse Drug Event Prevention
6
Medication Safety and Care Coordination
Sources: National Action Plan for Adverse Drug Event Prevention Armor BL, Wight AJ, Carter SM. Evaluation of Adverse Drug Events and Medication Discrepancies in Transitions of Care Between Hospital Discharge and Primary Care Follow‐Up. Journal of Pharmacy Practice 2016, Vol. 29(2) 132‐137. Last accessed 1/11/17 at http://journals.sagepub.com/doi/pdf/10.1177/0897190014549836 Cornish PL, Knowles SR, Marchesano R, et al. Unintended medication discrepancies at the time of hospital admission. Arch Intern Med. 2005;165:424‐429. Last accessed 1/11/17 at http://jamanetwork.com/journals/jamainternalmedicine/fullarticle/486421
7
http://jamanetwork.com/journals/jamainternalmedicine/fullarticle/486421http://journals.sagepub.com/doi/pdf/10.1177/0897190014549836
Community Discharge Medication List Program
Carrington, ND
Jesse Rue, PharmD Carrington Medical Center Matt Paulson, RPh
Carrington Drug Shane Wendel, PharmD
Central Pharmacy
8
Community Discharge Medication List Program
Goal of program: • Create the opportunity for the patient, clinic, hospital and pharmacy to have an identical medication list at time of discharge in our community
9
Community
Carrington, ND • Population: 2,065 • County Seat • Service areas include portions of 4 counties
10
Community
CHI St Alexius Health Carrington Medical Center • Critical Access Hospital • Attached clinic, ER, Same Day Care Center • Another clinic 15 miles north in New Rockford • Meditech EHR in hospital/ER • Allscripts AEHR in clinics
11
Community
Three Independent Community Pharmacies • Carrington Drug • Central Pharmacy Carrington • Central Pharmacy New Rockford
12
Program Design – Hospital and Clinic
Began in October 2015 Patient discharge medication list created inhospital at discharge includes • Drug name (brand and generic) • Directions for use • Indication
Copy created for hospital pharmacy and clinic Clinic staff reviews list and enters and changesinto the AEHR prior to patient’s post‐discharge clinic visit
13
Program Design – Community Pharmacy
With patient permission, hospital sends copy of medication list to designated local pharmacy Community pharmacy
• Reviews list for changes • Contacts patient to provide counseling or re‐labeling services, offer in‐person visit Standing order from local providers allows local pharmacies to provide updated labeling in certain circumstances for discharge dose change
• Fills out tracking form
14
Data Collection
19 data fields tracked by hospital pharmacy 9 data fields tracked by community pharmacy
15
Challenges
Pharmacy tracking forms needed several adjustments over first months – PDSA! Hospital staff turnover – Unaware of procedures Incomplete form from hospital staff Medication list not shared with local pharmacy Irregular hospital pharmacist engagement in hospital admission/discharge medication reconciliation
16
Opioid Safety
HRM ADE State Ranks (lower is better)
50
45
40
35
30
25
20
15
10
5
0 Anticoagulant ADE Diabetic Agent ADE Opioid ADE
HRM Hospital Admission State Ranks (lower is better)
50
45
40
35
30KS KS NE 25 NE ND 20 ND SD SD15
10
5
0 Anticoagulant Diabetic Agent Opioid Admissions Admissions Admissions
Source: QIN‐QIO National Coordinating Center based on 2013 Medicare Part A & D claims
17
Prescription Drug Monitoring Programs Melissa J. DeNoon, R.Ph. Prescription Drug Monitoring Program Director South Dakota State Board of Pharmacy
18
Prescription Drug Monitoring Programs (PDMPs) continue to be
among the most promising state‐level interventions to improve opioid
prescribing, inform clinical practice, and protect patients at risk.
SD PDMP History and General Information
The SD Prescription Drug Monitoring Program was established by the State Legislature in 2010 (SDCL 34‐20E) to improve patient care and to reduce diversion of dangerous drugs; operations began in March 2012 with data submitted retroactive to July 2011
PDMP Program Highlights • Dispensers “must” submit reports at least weekly to the database – with the
exception of federal facilities (VA, AFB, IHS) – which are not required to submit, although IHS and VA do submit
• Reports generated are tools in prescribers’ and dispensers’ practices to “improve patient care” and to aid prescribers, dispensers and law enforcement in preventing and detecting illicit use of prescription controlled drugs
• Overarching “Ultimate Goal” – Prevent overdose deaths due to prescription drugs while preserving access for those in need of narcotic pain relievers and other controlled substances
20
Integration—The Future of Prescription Drug Monitoring Programs
A solution via health IT for the underutilization of the considerable, important data collected by PDMPs
Integration of PDMP data into health system electronic health records (EHR) and pharmacy software systems Addresses a major concern of prescribers and pharmacists which is
accessing the PDMP requires additional steps that are not in the clinical workflow
Integration benefits include: Immediate improvement in the patient care process User workflows are streamlined and improved Pharmacist and prescriber satisfaction are highest when technology automates the
majority of workflow tasks
SD PDMP/Avera Meditech Integration
Medication Safety in Long Term Care
2014 OIG Report
Source: Adverse Events in SNFs: National Incidence among Medicare Beneficiaries, Department of Health and Human Services, Office of Inspector General report OEI‐06‐11‐00370. Last accessed 1/16/2017 at https://oig.hhs.gov/oei/reports/oei‐06‐11‐00370.pdf
23
https://oig.hhs.gov/oei/reports/oei-06-11-00370.pdf
Enhancing Medication Safety in the Long-Term Care
Setting Mackenzie Farr Community Pharmacy
Gretna, NE
What’s Happening Right Now?
Acuity is increasing in the long-term care facility setting Patient health needs are becoming more complex
Patients are discharging in a more fragile state
Lacking/Non-existent medication reconciliation processes
Trying to stay ahead of the ever-changing landscape
Challenges the Industry is Facing Handling the complex patient
Distance
Hospital formulary challenges
Hospitalists vs. Primary Care Physician orders
Private insurance
Are medications or prescriptions being sent with the resident upon discharge?
When will the resident be discharging?
Community Pharmacy Standards
Our Goal: To be the strongest link in the chain of transition We saw a need for ensuring the safe
transition from both the hospital and home setting into the long-term care setting
Work with prescribers and hospitals
Increasing our service offerings
Utilizing resources
Additional Efforts We Have Put in Place
Taking the lead to help clarify orders Taking the burden of addressing questions or issues
out of the hands of the facility
Working together to create partnerships with facilities
Leading the charge with medication reconciliation
Interfacing with EHR Systems
Dedicated pharmacy staff assigned to each facility
Continuing to Evolve
Continue to create partnerships Working with both facilities and prescribers
to navigate unfamiliar waters
Spreading the word Informing entities we partner with about
pharmacy requirements
Staying ahead of the curve Get involved!
Stay informed!
Questions and Discussion
Questions for our speakers • Via phone or chat • *2 to mute your line; *2 to unmute
30
Leave in Action
Questions to run on: • In what way(s) can medication safety be improved in your setting?
• What is one action you will take to improve medication safety in your setting?
31
Leave in Action
Website Resources • Great Plains QIN Care Coordination and Medication Safety Quarterly Report http://greatplainsqin.org/initiatives/coordination‐care/ Under Related Documents > Category – Tool
• Great Plains QIN Medication Safety Resources Links to many tools http://greatplainsqin.org/initiatives/medication‐safety/
32
http://greatplainsqin.org/initiatives/medication-safetyhttp://greatplainsqin.org/initiatives/coordination-care
Contact Information
Vanessa Lamoreaux, BA Project Manager [email protected] Kansas Foundation for Medical Care 2947 SW Wanamaker Drive Topeka, KS 66614‐4193 P: 785.271.4120
Paula Sitzman, RN, BSN Quality Improvement Advisor paula.sitzman@area‐a.hcqis.org CIMRO of Nebraska 1200 Libra Drive, Suite 102 Lincoln, Nebraska 68512 P: 402.476.1399, Ext. 512
Sally May, RN, BSN, CH‐GCN Senior Quality Improvement Specialist sally.may@area‐a.hcqis.org Jayme Steig, , PharmD, RPh Quality Improvement Specialist‐Pharmacy jayme.steig@area‐a.hcqis.org Quality Health Associates of North Dakota 3520 North Broadway Minot, ND 58703 P: 701.852.4231
Linda Penisten, RN, OTR/L Program Manager linda.penisten@area‐a.hcqis.org South Dakota Foundation for Medical Care 2600 West 49th Street, Suite 300 Sioux Falls, SD 57105 P: 605‐444‐4124
33
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
Coming Events . . .
February 28, 2017 12:00‐1:00 p.m. CT
Coaching Calls Medication SafetyCall: 888.585.9008
Passcode: 302681380 Go To Meeting: https://global.gotomeeting.com/join/873196077
Reducing RehospitalizationsCall: 888.585.9008
Passcode: 643345468 Go To Meeting: https://global.gotomeeting.com/join/570631117
Chronic Disease ManagementCall: 877.567.1262 Passcode: 6252783
Go To Meeting: https://global.gotomeeting.com/join/607233021
34
https://global.gotomeeting.com/join/607233021https://global.gotomeeting.com/join/570631117https://global.gotomeeting.com/join/873196077
Coming Events . . .
March 28, 2017 12:00‐1:00 p.m. CT
Chronic Disease Management
Click here to register.
All future events can be located on the Great Plains QIN calendar: http://greatplainsqin.org/calendar‐2/upcoming‐events/
This material was prepared by the Great Plains Quality Innovation Network, the Medicare Quality Improvement Organization for Kansas, Nebraska, North Dakota and South Dakota, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. 11S0W‐GPQIN‐ND‐C3‐96/0117
35
http://greatplainsqin.org/calendar-2/upcoming-events
Structure BookmarksFigureMedication Safety. by. CIMRO of Nebraska. Kansas Foundation for Medical Care. Quality Health Associates of North Dakota. South Dakota Foundation for Medical Care. January 24, 2017. FigureWelcome and Reminders. Figure
Welcome!
Q & As at end of presentations
Slides and recording will be available on the GPQIN website: Calendar > Past Events
http://greatplainsqin.org http://greatplainsqin.org http://greatplainsqin.org
*2 to mute your line; *2 to unmute
Utilize chat for questions and sharing
FigureFigureFigureMedication Safety. Figure3 Source: National Action Plan for Adverse Drug Event Prevention FigureMedication Safety. FigureAdmissions per 1,000 HRM Consumers Admissions per 1,000 HRM Consumers Admissions per 1,000 HRM Consumers
900.00 800.00 700.00 600.00 500.00 400.00 300.00 200.00 100.00 0.00 FigureOverall FFS Diabetic Agents Opioids Anticoagulants Overall FFS Diabetic Agents Opioids Anticoagulants Readmissions per 1,000 HRM Consumers
200.00 180.00 160.00 140.00 KS KSKSFigure
120.00 NE NE NE
100.00 ND ND ND SD
SD 80.00 Nation Nation 60.00 40.00 20.00 0.00 Overall FFS Diabetic Agents Opioids Anticoagulants Overall FFS Diabetic Agents Opioids Anticoagulants
Source: QIN‐QIO National Coordinating Center based on 2014 Medicare Part A & D claims FigureMedication Safety. Figure300 300 300 Probable ADE Rate Any Diagnosis Code 45 Probable ADE Rate Principal Diagnosis Code
TR40
250. ADE Rate per 1,000 HRM Consumers ADE Rate per 1,000 HRM Consumers 5 0 Anticoagulants Diabetic Agents Opioids KS NE NE NE NE NE NE NE NE NE NE ND
SD
Nation
KS
NE
ND
SD
Nation
35. 30. 25. SectFigureAnticoagulants Diabetic Agents Opioids Anticoagulants Diabetic Agents Opioids
Figure200. 150. 100. 20. 15. 10. Source: QIN‐QIO National Coordinating Center based on 2013 Medicare Part A & D claims FigureMedication Safety and Care Coordination. FigureSource: National Action Plan for Adverse Drug Event Prevention
Figure
Medication Safety and. Medication Safety and. Care Coordination Sources: National Action Plan for Adverse Drug Event Prevention Armor BL, Wight AJ, Carter SM. Evaluation of Adverse Drug Events and Medication Discrepancies in Transitions of Care Between Hospital Discharge and Primary Care Follow‐Up. Journal of Pharmacy Practice 2016, Vol. 29(2) 132‐137. Last accessed 1/11/17 at Cornish PL, Knowles SR, Marchesano R, et al. Unintended medication discrepancies at the time of hospital admission. Arch Intern Med. 2005;165:424‐429. Last accessed 1/11/17 at http://journals.sagepub.com/doi/pdf/10.1177/0897190014549836 http://journals.sagepub.com/doi/pdf/10.1177/0897190014549836
http://jamanetwork.com/journals/jamainternalmedicine/fullarticle/486421 http://jamanetwork.com/journals/jamainternalmedicine/fullarticle/486421
7 FigureCommunity Discharge. Medication List Program. Carrington, ND. Jesse Rue, PharmD. Jesse Rue, PharmD. Carrington Medical Center Matt Paulson, RPh. Carrington Drug Shane Wendel, PharmD. Central Pharmacy Figure
Community Discharge. Community Discharge. Medication List Program Goal of program:
•. Create the opportunity for the patient, clinic, hospital and pharmacy to have an identical medication list at time of discharge in our community 9 Community. FigureCarrington, ND
•. •. •. Population: 2,065.
•. •. County Seat
•. •. Service areas include portions of 4 counties
FigureFigureCommunity. FigureCHI St Alexius Health Carrington Medical Center.
• • • Critical Access Hospital
• • Attached clinic, ER, Same Day Care Center
• • Another clinic 15 miles north in New Rockford
• • Meditech EHR in hospital/ER
• • Allscripts AEHR in clinics
SectFigure
FigureCommunity. FigureThree Independent Community Pharmacies.
• • • • Carrington Drug
• • Central Pharmacy Carrington
• • Central Pharmacy New Rockford
Figure12
Program Design –Hospital and Clinic. Program Design –Hospital and Clinic. Figure
Began in October 2015
Patient discharge medication list created inhospital at discharge includes
• • • Drug name (brand and generic)
• • • Directions for use
• • Indication
Copy created for hospital pharmacy and clinic.
Clinic staff reviews list and enters and changesinto the AEHR prior to patient’s post‐discharge clinic visit
FigureProgram Design – Community Pharmacy. Program Design – Community Pharmacy. Figure
With patient permission, hospital sends copy of. medication list to designated local pharmacy.
Community pharmacy
•. •. •. Reviews list for changes
•. •. •. Contacts patient to provide counseling or re‐labeling services, offer in‐person visit
Standing order from local providers allows local pharmacies to provide updated labeling in certain circumstances for discharge dose change
•. •. Fills out tracking form
FigureData Collection. Figure
19 data fields tracked by hospital pharmacy
9 data fields tracked by community pharmacy.
FigureChallenges. Figure
Pharmacy tracking forms needed several. adjustments over first months – PDSA!.
Hospital staff turnover –Unaware of procedures.
Incomplete form from hospital staff
Medication list not shared with local pharmacy.
Irregular hospital pharmacist engagement in hospital admission/discharge medication reconciliation
FigureFigureOpioid Safety. FigureHRM ADE State Ranks HRM ADE State Ranks
(lower is better). 50. 45. 40. 35. 30. 25. 20. 15. 10. 5. 0. Anticoagulant ADE Diabetic Agent ADE Opioid ADE. FigureHRM Hospital Admission State Ranks HRM Hospital Admission State Ranks (lower is better). 50. 45. 40. 35. 30.KS. KS. NE 25. Figure
NE. ND. 20. ND SD SD15. 10. 5. 0 0 Anticoagulant Diabetic Agent Opioid Admissions
Admissions Admissions
Source: QIN‐QIO National Coordinating Center based on 2013 Medicare Part A & D claims FigurePrescription Drug Monitoring Programs FigureMelissa J. DeNoon, R.Ph. Prescription Drug Monitoring Program Director South Dakota State Board of Pharmacy Melissa J. DeNoon, R.Ph. Prescription Drug Monitoring Program Director South Dakota State Board of Pharmacy
FigurePrescription Drug Monitoring. Programs (PDMPs) continue to be. among the most promising state‐level. interventions to improve opioid. prescribing, inform clinical practice, and. protect patients at risk.. Figure
SD PDMP History and General Information. SD PDMP History and General Information. FigureThe SD Prescription Drug Monitoring Program was established by the State Legislature in 2010 (SDCL 34‐20E) to improve patient care and to reduce diversion of dangerous drugs; operations began in March 2012 with data submitted retroactive to July 2011 PDMP Program Highlights •. •. •. Dispensers “must” submit reports at least to the database –with the exception of federal facilities (VA, AFB, IHS) –which are not required to submit, although IHS and VA do submit weekly
•. •. Reports generated are tools in prescribers’ and dispensers’ practices to “improve patient care” to aid prescribers, dispensers and in preventing and detecting illicit use of prescription controlled drugs and law enforcement
•. •. Overarching “Ultimate Goal” –Prevent overdose deaths due to prescription drugs while preserving access for those in need of narcotic pain relievers and other controlled substances
FigureIntegration—The Future of Prescription. Drug Monitoring Programs. Figure
A solution via health IT for the underutilization of the. considerable, important data collected by PDMPs.
Integration of PDMP data into health system electronic health records (EHR) and pharmacy software systems
Addresses a major concern of prescribers and pharmacists which is accessing the PDMP requires additional steps that are not in the clinical workflow
Integration benefits include:
Immediate improvement in the patient care process
User workflows are streamlined and improved
Pharmacist and prescriber satisfaction are highest when technology automates the majority of workflow tasks
FigureFigureSD PDMP/Avera Meditech. Integration. Figure
Medication Safety in Long Term Care. Medication Safety in Long Term Care. 2014 OIG Report Source: Adverse Events in SNFs: National Incidence among Medicare Beneficiaries, Department of Health and Human Services, Office of Inspector General report OEI‐06‐11‐00370. Last accessed 1/16/2017 at https://oig.hhs.gov/oei/reports/oei‐06‐11‐00370.pdf https://oig.hhs.gov/oei/reports/oei‐06‐11‐00370.pdf
23 Enhancing Medication Safety in the Long-Term Care Setting Mackenzie Farr Community Pharmacy Gretna, NE FigureWhat’s Happening Right Now?
Acuity is increasing in the long-term care facility setting
Patient health needs are becoming more complex
Patients are discharging in a more fragile state
Lacking/Non-existent medication reconciliation processes
Trying to stay ahead of the ever-changing landscape
FigureFigureChallenges the Industry is Facing
Handling the complex patient
Distance
Hospital formulary challenges
Hospitalists vs. Primary Care Physician orders
Private insurance
Are medications or prescriptions being sent with the resident upon discharge?
When will the resident be discharging? .
FigureFigureCommunity Pharmacy Standards
Our Goal: To be the strongest link in the chain of transition
We saw a need for ensuring the safe transition from both the hospital and home setting into the long-term care setting
Work with prescribers and hospitals
Increasing our service offerings
Utilizing resources
FigureFigureAdditional Efforts We Have Put in Place
Taking the lead to help clarify orders
Taking the burden of addressing questions or issues out of the hands of the facility
Working together to create partnerships with facilities
Leading the charge with medication reconciliation
Interfacing with EHR Systems
Dedicated pharmacy staff assigned to each facility
FigureFigureContinuing to Evolve
Continue to create partnerships
Working with both facilities and prescribers to navigate unfamiliar waters
Spreading the word
Informing entities we partner with about pharmacy requirements
Staying ahead of the curve
Get involved!
Stay informed!
FigureQuestions and Discussion. FigureQuestions for our speakers
• Via phone or chat • *2 to mute your line; *2 to unmute FigureLeave in Action. FigureQuestions to run on:
•. •. •. In what way(s) can medication safety be improved in your setting?
•. •. What is one action you will take to improve. medication safety in your setting?.
FigureLeave in Action. FigureWebsite Resources
•. •. •. •. Great Plains QIN Care Coordination and Medication Safety Quarterly Report
/ / http://greatplainsqin.org/initiatives/coordination‐care
Under Related Documents > Category – Tool
•. •. •. Great Plains QIN Medication Safety Resources
Links to many tools
/ / http://greatplainsqin.org/initiatives/medication‐safety
FigureContact Information. Contact Information. FigureVanessa Lamoreaux, BA Project Manager [email protected] [email protected] [email protected]
Kansas Foundation for Medical Care 2947 SW Wanamaker Drive Topeka, KS 66614‐4193 P: 785.271.4120 Paula Sitzman, RN, BSN Quality Improvement Advisor paula.sitzman@area‐a.hcqis.org paula.sitzman@area‐a.hcqis.org paula.sitzman@area‐a.hcqis.org
CIMRO of Nebraska 1200 Libra Drive, Suite 102 Lincoln, Nebraska 68512 P: 402.476.1399, Ext. 512 Sally May, RN, BSN, CH‐GCN Senior Quality Improvement Specialist sally.may@area‐a.hcqis.org sally.may@area‐a.hcqis.org sally.may@area‐a.hcqis.org
Jayme Steig, , PharmD, RPh Quality Improvement Specialist‐Pharmacy jayme.steig@area‐a.hcqis.org jayme.steig@area‐a.hcqis.org jayme.steig@area‐a.hcqis.org
Quality Health Associates of North Dakota 3520 North Broadway Minot, ND 58703 P: 701.852.4231 Linda Penisten, RN, OTR/L Program Manager linda.penisten@area‐a.hcqis.org linda.penisten@area‐a.hcqis.org linda.penisten@area‐a.hcqis.org
South Dakota Foundation for Medical Care 2600 West 49th Street, Suite 300 Sioux Falls, SD 57105 P: 605‐444‐4124 33 FigureComing Events . . .. FigureFebruary 28, 2017 12:00‐1:00 p.m. CT February 28, 2017 12:00‐1:00 p.m. CT
Coaching Calls
Medication SafetyMedication SafetyCall: 888.585.9008. Passcode: 302681380. Go To Meeting: https://global.gotomeeting.com/join/873196077. https://global.gotomeeting.com/join/873196077.
Reducing RehospitalizationsReducing RehospitalizationsCall: 888.585.9008. Passcode: 643345468. Go To Meeting: https://global.gotomeeting.com/join/570631117. https://global.gotomeeting.com/join/570631117.
Chronic Disease ManagementChronic Disease ManagementCall: 877.567.1262 Passcode: 6252783 Go To Meeting: https://global.gotomeeting.com/join/607233021 https://global.gotomeeting.com/join/607233021
Coming Events . . .. FigureMarch 28, 2017. 12:00‐1:00 p.m. CT. Chronic Disease Management. Click to register.. here
All future events can be located on the Great Plains QIN calendar: / / http://greatplainsqin.org/calendar‐2/upcoming‐events
This material was prepared by the Great Plains Quality Innovation Network, the Medicare Quality Improvement Organization for Kansas, Nebraska, North Dakota and South Dakota, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The contents presented do not necessarily reflect CMS policy. 11S0W‐GPQIN‐ND‐C3‐96/0117 35