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As CMS continues shifting Star Ratings and quality programs toward outcomes-based performance, medication safety has become an increasingly important area of focus for health plans. The introduction of the Concurrent Use of Opioids and Benzodiazepines (COB) and Polypharmacy: Use of Multiple Anticholinergic Medications in Older Adults (Poly-ACH) measures reflects a broader industry movement toward identifying preventable medication-related risks before they lead to adverse events, avoidable utilization or poor member outcomes.
Unlike traditional adherence measures, these patient safety measures introduce new operational and clinical complexities. They require plans to navigate provider coordination challenges, overlapping prescribing patterns, behavioral health considerations and sensitive member engagement conversations—often across fragmented care settings.
For many organizations, the questions extend beyond measure specifications alone:
- What interventions are most effective?
- How should plans approach clinically appropriate overlap?
- How early should organizations intervene?
- How might success be measured beyond Star Ratings performance?
The following FAQ addresses some of the most common questions health plans are asking as they prepare for and operationalize these new medication safety measures.
Measure Fundamentals
Why is CMS placing greater emphasis on medication safety measures now?
CMS is increasingly focused on measures that reflect real-world patient safety risks and avoidable adverse events. Concurrent opioid and benzodiazepine use, as well as anticholinergic polypharmacy, are associated with an increased risk of falls, cognitive impairment, overdose, hospitalization and mortality—particularly among older adults.
These measures also reflect the broader shift by CMS toward outcomes-focused quality programs that reward plans for improving member safety, reducing avoidable utilization and supporting appropriate prescribing practices.
What makes these measures particularly challenging for health plans?
These measures are complex because they involve unique medication utilization overlap timing along with multiple prescribers, pharmacies and care settings. In many cases, providers may not have full visibility into a member’s complete medication regimen or prescribing history, much less the idiosyncrasies of measure qualification or failure.
Many impacted members may also have chronic pain, behavioral health conditions or longstanding medication regimens that require thoughtful coordination and sensitive clinical decision-making. Addressing these measures successfully requires organizations to identify risk early, coordinate outreach across providers and engage members carefully without disrupting appropriate therapy.
Building your strategy around patient safety measures? Check out our webinar replay for details! Prepare for CMS Patient Safety Measures
Clinical Considerations
In your experience, how do you determine the classes of medication you recommend members stop taking versus the ones that can be shifted to a safer alternative?
AdhereHealth’s role is not to recommend specific medications for discontinuation or replacement. Instead, we identify the medications contributing to measure risk and help ensure providers have visibility into potential safety concerns.
Clinical decisions regarding tapering, discontinuation or therapeutic alternatives should remain between the provider and the member, based on the individual’s clinical needs and treatment goals.
How should organizations handle situations where medications are clinically appropriate despite measure risk?
These measures should never replace clinical judgment. Sometimes, concurrent therapy or certain medications may be medically necessary and appropriate for an individual member.
The goal is not to eliminate appropriate treatment, but to ensure risks are recognized, coordinated, monitored and thoughtfully managed. Medication safety programs should support informed decision-making rather than rigid adherence to measure performance alone.
What is the most important factor in preventing a 30-day overlap event?
Timing is one of the biggest factors. The earlier organizations identify a potential overlap risk, the more options they have to intervene before the member qualifies for the measure.
Plans that wait until a member already meets the threshold often have fewer opportunities to coordinate changes or engage providers effectively. Regular monitoring of pharmacy and medical claims can help organizations identify concerning patterns earlier and prioritize outreach before intervention windows begin to close.
Provider Engagement and Care Coordination
How should plans approach provider outreach when multiple prescribers are involved in medication safety risk?
The appropriate outreach target often depends on which providers are prescribing the medications involved in the polypharmacy or overlap risk. Reviewing prescribing data at the NPI level can help determine where to direct outreach.
It is important to engage all relevant prescribers. For example, if one provider is prescribing an opioid and another is prescribing a benzodiazepine, outreach to both providers is often necessary to ensure coordination and shared visibility.
It can be difficult to get a provider on the phone. What do you find is the most effective type of outreach?
Provider outreach tends to be most effective when it is concise, actionable and integrated into existing workflows whenever possible.
Omnichannel approaches that rely on a combination of phone outreach, EHR messaging and fax communication help address provider preferences and availability. The goal is not simply to generate awareness, but to make it easier for providers to quickly understand the issue, evaluate the member’s situation and determine whether follow-up is needed.
How do you approach provider outreach without creating administrative burden or alert fatigue?
Effective outreach should:
- Clearly identify the member and issue medications
- Explain the quality or safety concern
- Provide relevant timing information
- Support clinical decision-making without dictating treatment
Behavioral science–informed communication can also improve response rates by reducing friction and making requested actions easier to understand and complete.
What role do pharmacists play in improving performance on these measures?
Pharmacists are often critical partners because they have visibility into medication histories, refill timing, therapeutic duplication and potential drug interactions.
Pharmacists can:
- Identify high-risk medication combinations
- Support medication reviews
- Reinforce member education
- Facilitate communication with prescribers
- Recommend opportunities for safer alternatives when clinically appropriate
Their accessibility and medication expertise make them valuable collaborators in medication-safety initiatives.
Member Engagement and Behavioral Science
How do you engage members without making them feel like medications are being “taken away”?
Conversations with members should focus on safety and support, rather than compliance or restriction.
Members are often more receptive when outreach acknowledges their experiences, encourages discussion with their provider and avoids language that feels alarming or judgmental. The goal is not to pressure members into medication changes, but to support informed conversations around safety, quality of life and appropriate medication use under clinical supervision.
What role does behavioral science play in medication safety outreach?
Medication safety conversations can be sensitive for both providers and members. Communication style matters.
Small changes in tone, timing and message framing can make outreach feel more supportive and improve engagement. Organizations that communicate clearly and reduce unnecessary friction often see stronger responsiveness from both providers and members.
Engage members in adherence for lasting success: learn more within our e-book! Four Core Strategies that Turn Engagement into Lasting Success
Data, Analytics and Performance Strategy
Once a member qualifies, they are “stuck” within that measure. How do you reconcile the right thing to do and the “gamification” of measures?
These measures are ultimately designed to improve patient safety, so manipulating prescribing patterns to dilute performance would not be an appropriate strategy.
Organizations can improve performance more effectively by:
- Identifying provider prescribing patterns
- Prioritizing proactive intervention
- Educating providers on high-risk medication combinations
- Monitoring claims activity regularly
- Coordinating care across the continuum
Focusing on safer prescribing and earlier intervention supports both better member outcomes and stronger measure performance.
How can plans identify provider “hot spots” or prescribing patterns?
Analyzing pharmacy and medical claims data can help organizations identify providers, specialties or geographic areas associated with higher concentrations of impacted members or prescribing behaviors.
This type of visibility allows plans to prioritize outreach and education efforts more strategically rather than approaching all providers the same way.
What metrics should organizations track internally beyond Star Ratings performance?
Looking beyond measure performance alone can provide a more complete view of program effectiveness.
Many organizations monitor operational indicators such as members approaching overlap thresholds, outreach completion rates and provider responsiveness alongside clinical outcomes like successful deprescribing interventions, medication switches to safer alternatives or adverse drug event-related utilization.
Tracking both operational and clinical trends can help plans better understand where interventions are working and where additional support may be needed.
What differentiates organizations that are most successful with these measures?
Organizations that perform well typically:
- Identify risk early
- Use data proactively rather than retrospectively
- Coordinate communication across providers and pharmacies
- Incorporate behavioral-science principles into outreach
- Align operational and clinical teams
- Focus on member-centered engagement
- Treat the measures as patient safety initiatives, not just quality metrics
Final Thoughts:
The introduction of COB and Poly-ACH represents more than the addition of new Star Ratings measures. It signals a continued shift toward proactive medication safety management and more coordinated, outcomes-focused care.
Organizations that succeed with these measures will likely be those that move beyond retrospective reporting and adopt earlier risk identification, stronger provider coordination and more member-centered engagement strategies. Success requires balancing measure performance with thoughtful clinical decision-making while supporting providers and members through complex medication-related conversations.
As health plans continue preparing for these evolving expectations, medication safety programs will increasingly depend on the ability to combine analytics, clinical expertise, workflow integration and behavioral science-informed engagement into a cohesive strategy.
AdhereHealth helps health plans address medication safety challenges by aligning data, provider outreach and human-centered engagement strategies to support safer prescribing practices and better long-term outcomes. To learn more, contact us today!
