CMS Clarifies Who Can Assess Chronic Narcotic Use—Here’s What That Means for You

Hospitals across the country are asking the same question. The answer may be simpler—and more manageable—than expected.

Initially, CMS’s guidance around who could report chronic narcotic use left many hospitals assuming the responsibility fell solely to physicians or advanced practice providers. That interpretation created a workflow burden and added friction in already time-constrained clinical environments—especially for organizations trying to maintain momentum with PROMs adoption.

Now, CMS has clarified: non-physician providers, including registered nurses, can assess and document chronic opioid use—provided it’s within their scope of practice and supported by their organization’s internal policy. This shift allows hospitals to embed the task into existing workflows, reduce strain on providers, and collect compliant, audit-ready data without overhauling their approach.

Clarifying the Details of Chronic Narcotic Use Reporting

Does it require a licensed provider (MD, DO, PA, NP)?

No. According to CMS FAQs and confirmed by industry experts:

• The “Chronic Narcotic Use” data element must come from the medical record/EHR.
• It must be provider-reported, meaning the assessment originates from someone with clinical judgment—even if it’s a registered nurse (RN)—working within their scope of practice.
• CMS guidance clarifies that if an RN assesses the patient’s narcotic use accurately and in line with the definition, that’s acceptable.

Can this be collected through a survey or intake form?

Patient responses can help inform the assessment, but the final determination—labeling it as “Chronic Narcotic Use” or not—must be clinically confirmed by a provider using their professional judgment. Without provider validation, the data is considered incomplete and will not count toward compliance.

What qualifies as chronic narcotic use?

CMS defines it as daily or regular intermittent use of opioids (morphine-equivalent) for at least 90 days prior to THA or TKA. It reflects overall opioid use—not just for joint pain—and only the 90-day period leading up to the procedure.

Why This Matters

Accurate Risk Adjustment: Chronic narcotic use is one of the key factors CMS uses to adjust a facility’s performance scores under the PRO-PM. If this information is misreported—or missing entirely—it can affect how your outcomes are risk-adjusted, potentially lowering your improvement rates. Worse, inaccurate documentation could result in patients being excluded from compliance calculations or flagged during audit.

Workflow Efficiency: Knowing that RNs can collect and assess this data—when allowed by state scope and hospital policy—streamlines data collection without sacrificing quality.

Audit Readiness: The chronic narcotic use element is subject to CMS audit, just like other components of the PRO-PM. CMS requires clear documentation showing that a provider confirmed whether the patient met the chronic use criteria. If this information is missing or undocumented—even if the patient completed both the pre-op and post-op PROM surveys—the case won’t count toward your compliance rate. In other words, a fully-completed patient episode can be invalidated by a single missing risk variable. Over time, enough of these exclusions can drag down your compliance performance and can put you at risk for loss of Medicare revenue. That’s why it’s critical to ensure this data element is collected accurately and documented consistently.

Aligns with Established Workflows: Initially, many hospitals assumed this element had to be documented by a physician or advanced practice provider, which added unnecessary burden to already time-constrained clinical teams. In reality, chronic narcotic use is often identified during routine intake or pre-op screening—tasks commonly handled by nursing staff.

By allowing RNs (when within scope and supported by policy) to assess and document this data element, CMS is enabling organizations to align data collection with existing workflows. That means:

• Less disruption for surgeons and providers
• Faster, more consistent documentation
• A clearer path to accurate, audit-ready reporting

This clarification allows organizations to reduce friction, improve efficiency, and collect more accurate data—without pulling physicians away from patient care.

What’s Made This Even Harder for Hospitals?

This requirement has caught many organizations and EHR vendors off guard. In most EHRs, Chronic Narcotic Use wasn’t previously a discrete, reportable field. Even when major vendors like Epic introduced one, it often landed in workflows that didn’t align with how hospitals were actually collecting the information. As a result, many health systems have had to involve their IT teams to create or relocate the field—ensuring it appears in a part of the workflow where nurses or clinical staff can document it accurately and consistently.

This added technical lift has made clarity on who can collect and confirm the information even more critical. The more aligned the workflow, the higher the capture rate—and the lower the risk of falling out of compliance.

Simplifying the Process: What It Looks Like with CODE on Your Team

For hospitals collecting the Chronic Narcotic Use data element, clarity around roles and workflows is essential. If you’re working with CODE, we’ve already built these best practices into our service model—so you can stay focused on patient care while we ensure compliance and audit readiness.

Here’s a sample of how CODE clients are collecting the Chronic Narcotic Use data:

• During the anesthesia evaluation prior to surgery
• As part of the nursing portion of the pre-surgical appointment
• When the pharmacy team contacts patients pre-operatively to review their medication list
• Integrated into the pre-op nurse’s standard workflow
• A patient phone interview with an RN during pre-admission testing

Final Takeaway

CMS allows flexibility in who can assess chronic narcotic use, and RNs are fully appropriate data collectors—so long as the assessment reflects clinical judgment and scope. If you’re not a CODE client and are struggling to meet the CMS THA/TKA PRO-PM, you don’t have to build this from scratch. We manage the collection, ensure documentation aligns with CMS requirements, and prepare your data for audit—without adding burden to your team.

Let us handle the operational complexity so you can focus on outcomes.