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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations
process to propose measures for removal or replacement, as we described upon adopting these factors in the FY 2018
IPPS/LTCH PPS final rule 82 FR 38464
through 38465.
In the FY 2022 IPF PPS proposed rule we described that in our continual evaluation of the IPFQR Program measure set under our Meaningful Measures Framework and according to our measure removal and retention factors, we identified four measures that we believed were appropriate to propose removing from the IPFQR
Program for the FY 2024 payment determination and subsequent years 86
FR 19507. Our discussion of these measures follows.
2. Measures Proposed for Removal in the FY 2022 IPF PPS Proposed Rule a. Retention of the Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention SUB
2/2a Measure Beginning With FY 2024
Payment Determination We proposed to remove the Alcohol Use Brief Intervention Provided or Offered SUB2 and subset measure Alcohol Use Brief Intervention SUB2a collectively referred to as the SUB2/2a measure from the IPFQR Program beginning with the FY 2024 payment
determination under our measure removal Factor 8, The costs associated with a measure outweigh the benefit of its continued use in the program. We adopted the Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention SUB
2/2a measure in the FY 2016 IPF PPS
final rule 80 FR 46699 through 46701
because we believe it is important to address the common comorbidity of alcohol use among IPF patients. This measure requires facilities to chartabstract measure data on a sample of IPF
patient records, in accordance with established sampling policies 80 FR
46717 through 46719.
We have previously stated our intent to move away from chart-abstracted measures to reduce information collection burden in this and other CMS
quality programs 78 FR 50808; 79 FR
50242; 80 FR 49693. When we adopted the SUB2/2a measure to the IPFQR
Program, the benefits of this measure were high because IPF performance was not consistent. Therefore, the measure provided a means of distinguishing IPF
performance and incentivized facilities to improve rates of treatment for this common comorbidity. Between the FY
2018 payment determination the first year that SUB2/2a was included in the
IPFQR Program measure set and the FY
2019 payment determination, we saw substantial performance improvement on the SUB2 measure which is the portion of the SUB2/2a measure that assesses whether the IPF provided or offered a brief intervention for alcohol use. However, for the FY 2019 and FY
2020 payment determinations, the rate of improvement has leveled off to consistently high performance, as indicated in Table 3. These data further show that at this time there is little room for improvement in the SUB 2
measure, and that the quality improvement benefits from the measure have greatly diminished.
As stated in the proposed rule, we continue to believe that alcohol use is an important comorbidity to address in the IPF setting, and that brief interventions are a key component of addressing this comorbidity. However, based on these data, we believe that most IPFs routinely offer alcohol use brief interventions, and that IPFs will continue to offer these interventions to patients, regardless of whether the SUB
2/2a measure is in the IPFQR Program measure set, because it has become an embedded part of their clinical workflows.

Year
Mean
Median
75th percentile
90th percentile
2016 2018 Payment Determination 2017 2019 Payment Determination 2018 2020 Payment Determination
66.96
77.11
79.49

77

96
99
100

100
100
100

In the proposed rule, we noted that while the measure does not meet our criteria for topped-out status because of the TCV higher than 0.1, we believe that this measure no longer meaningfully supports the program objectives of informing beneficiary choice and driving improvement in IPF
interventions for alcohol use because it is no longer showing significant improvement in IPF performance that is, in providing or offering alcohol use brief interventions. Furthermore, as we stated in the FY 2019 IPF PPS final rule, costs are multi-faceted and include not only the burden associated with reporting, but also the costs associated with implementing and maintaining the program 83 FR 38592. For example, it may be costly for health care providers to maintain general administrative
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knowledge to report this measure.
Additionally, CMS must expend resources in maintaining information collection systems, analyzing reported data, and providing public reporting of the collected information.
Here, IPF information collection burden and related costs associated with reporting the SUB 2/2a measure to CMS
are high because it is a chart-abstracted measure. Furthermore, CMS incurs costs associated with the program oversight of the measure for public display. As a result, we believe that the costs and burdens associated with this chartabstracted measure outweigh the benefit of its continued use in the program.
Therefore, we proposed to remove the Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention SUB2/2a measure from
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Truncated Coefficient of Variation TCV
0.49
0.28
0.25

the IPFQR Program beginning with the FY 2024 payment determination. We welcomed public comments on our proposal to remove the SUB2/2a measure from the IPFQR Program.
We received the following comments on our proposal.
Comment: Many commenters supported our proposal to remove the Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention SUB2/2a measure. Some commenters agreed with our rationale that the costs of this measure outweigh the benefit of its continued use in the IPFQR Program. A few commenters recommended that CMS remove the measure immediately, rather than beginning with FY 2024 payment determination as proposed, to further reduce burden. One commenter agreed
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TABLE 3: -Performance Analysis for Alcohol Use Brief Intervention Provided or Offered SUB-2