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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations that providers will continue these interventions after the measure has been removed. Another commenter also supported removal because the measure is no longer NQF endorsed and was not specified for this setting.
Response: We thank the commenters for their support. While we continue to believe that the performance on the SUB2/2a measure in recent years indicates that IPFs routinely offer alcohol use brief interventions, we recognize that we will not be able to monitor whether IPFs continue these interventions if we remove this measure. We considered proposing to remove the measure sooner, but because data are currently being collected to report during CY 2022 to inform the FY
2023 payment determination, we proposed removing the measure following that payment determination, that is, for the FY 2024 payment determination.
The commenter is correct that the measure is no longer NQF endorsed and is not specified for the IPF setting.
However, we continue to believe that this measure is appropriate for the IPF
setting. We reiterate that we proposed to remove this measure because of the belief that the costs of the measure outweigh its continued benefits in the IPFQR Program, not because it is no longer NQF endorsed nor because it was not specified for this setting.
Comment: One commenter supported removal of the SUB2/2a measure, but recommended development of more meaningful measures than SUB2/2a and the Alcohol & Other Drug Use Disorder Treatment Provided or Offered at Discharge and Alcohol & Other Drug Use Treatment at Discharge SUB3/3a measure to address screening and intervention for substance use. Another commenter recommended that CMS
consult with consumers to ascertain the benefits of measures in the IPFQR
Program prior to proposing to remove any such measures, this commenter specifically recommended that CMS not finalize removal of the SUB2/2a measure until fully considering input from consumers.
Response: We appreciate this commenters input and are continually seeking to improve our measure set by developing more meaningful and less burdensome measures. As we evaluate areas appropriate for measure development, we will consider additional measures or measure concepts that more meaningfully address alcohol use disorder treatment for the IPF patient population.
In response to the request that we consult with consumers to ascertain the benefits of the measure, we note that we
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evaluate input from all stakeholders, including consumers, patients, caregivers, and patient advocacy groups that we receive in response to our proposals to adopt or remove measures from the IPFQR Program. As part of this process, we have reviewed input from consumers regarding the benefits of the measure and considered this input in our analysis.
Comment: Some commenters expressed concern about removing the measure. A few of these commenters stated that not all facilities perform well on the measure and, therefore, there is still room for improvement. One commenter stated that the COVID19
pandemic has led to increased alcohol use and expressed the belief that removing the measure now is poorly timed.
Response: We note that we proposed to remove the measure because of the belief that the benefits of retaining it have lessened to the point that its costs outweigh those benefits, not because the measure is topped out. We agree with commenters that not all facilities perform uniformly well on the Alcohol Use Disorder Brief Intervention Provided or Offered and Alcohol Use Disorder Brief Intervention Provided SUB2/2a measure.
We also agree that alcohol use has increased during the COVID19
pandemic.152 153 154 In our literature review regarding this comment, we also identified evidence that individuals with mental health and substance use conditions may be at an increased risk of COVID19 complications and appropriate substance use disorder treatment may help mitigate these complications.155 156 To ensure that providers would continue to address 152 Pollard et. al., Changes in Adult Alcohol Use and Consequences During the COVID19 Pandemic in the US, JAMA Network Open, 2020;39:e2022942. doi:10.1001/
jamanetworkopen.2020.22942.
153 Alcohol Consumption Rises Sharply During Pandemic Shutdown; Heavy Drinking by Women Rises 41%, RAND, https www.rand.org/news/
press/2020/09/29.html.
154 Nemani et al., Association of Psychiatric Disorders With Mortality Among Patients With COVID19, JAMA Psychiatry. 2021;784:380386.
doi:10.1001/jamapsychiatry.2020.4442; COVID19
and people at increased risk, CDC, https
www.cdc.gov/drugoverdose/resources/covid-drugsQA.html; U. Saengow et. al.
155 Wang et. al., COVID19 risk and outcomes in patients with substance use disorders: Analyses from electronic health records in the United States, Molecular Psychiatry volume 26, pages 3039
2021, https www.nature.com/articles/s41380020-00880-7.
156 Vai et. al., Mental disorders and risk of COVID19-related mortality, hospitalisation, and intensive care unit admission: A systematic review and meta-analysis, Lancet Psychiatry, https
www.thelancet.com/pdfs/journals/lanpsy/PIIS221503662100232-7.pdf.

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alcohol use disorders among this patient population, we have maintained the Alcohol & Other Drug Use Disorder Treatment Provided or Offered at Discharge and Alcohol & Other Drug Use Treatment at Discharge SUB3/3a measure. However, we note that a prominent model to ensure those with alcohol use disorder are identified and referred to treatment include both brief interventions and referrals.157 Given the increased need for alcohol use brief interventions due to the pandemic, the current performance levels 158 for FY
2018 payment determination, the mean performance nationally was approximately 80 percent of patients who screened positive for alcohol use disorder were offered or provided a brief intervention, and the importance of providing alcohol use brief interventions to improve the efficacy of alcohol use treatment at discharge, we believe that the benefits of retaining the Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention SUB2/2a measure are greater than we initially estimated in our proposal to remove this measure and that the measure should not be removed from the program at this time.
Comment: One commenter observed that this measure may be useful for future stratification based on race and ethnicity.
Response: We agree with the commenter that this measure may be useful for future stratification based on race and ethnicity. While we do not believe it would be appropriate to retain this measure specifically for the purpose of potential future stratification, we agree that this potential is another benefit of the measure that we had not considered in our previous analysis of the benefits versus the costs of retaining the measure.
Comment: One commenter observed that there are benefits to retaining this measure because IPFs and health systems use performance data on this measure as part of quality improvement initiatives to reduce alcohol use and that removal may affect these programs.
Response: We thank the commenter for this input. We note that IPFs are responsible for abstracting the data for this measure, so we believe that IPFs who use these data for their own quality improvement initiatives have access to these data regardless of whether the measure is in the IPFQR Program.
157 https www.samhsa.gov/sbirt; https
www.samhsa.gov/sbirt/coding-reimbursement.
158 For FY 2018 payment determination, the mean performance nationally was approximately 80
percent of patients who screened positive for alcohol use disorder were offered or provided a brief intervention.

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