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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations Care attestation measure in the FY 2019
IPF PPS final rule 83 FR 38596 we stated that we believed we had collected sufficient information to inform development of a patient experience of care measure that would capture data on the results of such a survey. In the FY
2020 IPF PPS proposed rule 84 FR
16986 through 16987, we solicited input on how providers had implemented the Hospital Consumer Assessment of Healthcare Providers and Systems HCAHPS survey in their facilities. We also sought public comment on other potential surveys that commenters believed would be appropriate to adopt for the IPFQR
Program. We received many comments on this subject, and many of these comments expressed that there is not one survey used predominantly across IPFs 84 FR 38467. Additional commenters expressed concerns that the HCAHPS survey may not be appropriate for the IPF setting because it does not include some of the unique aspects of inpatient psychiatric care including, group therapy, non-physician providers, and involuntary admissions. While we did not solicit public comment on this issue in the FY 2021 IPF PPS proposed rule, we received many comments addressing this issue 85 FR 47043. We continue to seek to identify a minimally burdensome patient experience of care instrument that would be appropriate for the IPF setting. Therefore, in the FY
2022 IPF PPS proposed rule 86 FR
19511 through 19512 we sought public comment on instruments currently in use in the IPF setting, input on whether the HCAHPS survey may be appropriate for this setting, and information on how facilities that currently use the HCAHPS
survey have addressed challenges with using this survey within this setting that is, concerns regarding unique aspects of inpatient psychiatric care.
We received the following comments in response to our request.
Comment: Many commenters expressed support for development of a uniform patient experience of care measure because this is a gap in the IPFQR measure set. Many commenters expressed that there is currently no patient experience of care measure in the IPFQR Program and expressed the belief that such a survey could improve provider accountability, show respect for patients, and drive quality improvement. Some commenters observed that patients should be given the opportunity to share their experiences regardless of diagnosis. One commenter observed that evaluations of patient experience of care can be a driver of health equity.

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Many commenters shared personal or family experiences in IPFs and indicated that being able to share such experiences in a formal survey would allow patients and caregivers to have a voice, provide valuable feedback, feel respected, provide information for quality improvements, and inform other potential patients. One commenter observed that allowing proxies would be valuable. Some commenters observed that not collecting patient experience of care data leads to the perception that patients opinions are not valid and expressed the concern that this message may further objectify and traumatize a vulnerable patient population in a stressful and potentially stigmatizing situation that is, psychiatric hospitalization. Other commenters expressed that not collecting such data normalizes poor treatment of psychiatric patients. Some commenters observed that patients with psychiatric illness are not less likely to be competent to express their experience of care than patients with other acute care needs.
Many commenters recommended that CMS identify a minimum set of items to include in surveys, as opposed to requiring a specific survey. These commenters observed that the net promoter score NPS used by the National Health Service in the UK may be a good model to consider. Some commenters observed that many facilities have designed their own surveys tailored to their patient populations for example, pediatric patients, involuntarily admitted, etc.
and that it would be preferable for these facilities to add questions to meet a minimum set rather than to replace their surveys.
Many commenters expressed that they do not support HCAHPS for the IPF
setting. These commenters expressed that 1 the HCAHPS was developed for patients with non-psych primary diagnoses and not for behavioral health diagnoses therefore the questions on HCAHPS do not address patients top concerns regarding IPF care; 2 the survey protocols which allow for administration of the survey up to 6
weeks post-discharge may negatively impact completion rates due to the transient nature of the patient population; 3 the protocols do not have a web-interface for survey administration nor email or text survey invites; and 4 HCAHPS does not account for involuntary admissions.
Some commenters also expressed concern that HCAHPS is not validated, nor has it been through psychometric testing in this setting. Some commenters observed the HCAHPS survey is due for a redesign and observed that CMS could
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potentially address concerns with the HCAHPS survey as part of the intended redesign. Other commenters recommended that CMS develop a survey unique to this setting that addresses aspects of care specific to the setting such as group therapy, treatment by therapists, involuntary admission, medication treatment, consistency of treatment. One commenter recommended that CMS
collaborate with AHRQ in survey design and development. Some commenters recommended that CMS ensure proper risk adjustment because patient characteristic can affect patient experience.
Some commenters observed that the questions on HCAHPS apply to IPF
patients and recommended that CMS
test HCAHPS for this setting. A few of these commenters observed that using the same measure across settings would improve behavioral health parity, facility comparison, and reduce burden for facilities that are distinct part units in acute care hospitals that use HCAHPS. A few commenters expressed concern that excluding psychiatric patients from HCAHPS is discrimination based on a disability which, because of the benefits derived from patient experience surveys, denies patients with psychiatric diagnoses equal treatment. Other commenters observed that minimizing burden is not a factor in establishing patient experience of care measures in other settings and that therefore it should not be a consideration in this setting. Some commenters observed that CMS has requested and received input on this subject for several years and requested a specific plan of action.
A few commenters recommended that CMS collaborate with IPFs to determine how to assess patients experience of care, several commenters recommended that CMS establish a technical expert panel TEP with IPF members.
One commenter recommended that CMS reintroduce the attestation measure until a solution for assessing patient experience of care is identified.
Response: We thank these commenters for their input. We agree that Patient Experience of Care is a gap in the current IPFQR Program measure set and we agree with commenters that adoption of such a measure would be a meaningful step towards ensuring that patients have a voice regarding the care they receive. We appreciate the input from patients and their caregivers explaining how meaningful such a measure would be for these stakeholders. We intend to use the feedback provided here and in past requests to identify the most appropriate
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