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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations 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 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 this measure to CMS are high because the measure 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 Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment TOB2/2a measure from the IPFQR
Program beginning with the FY 2024
payment determination. We welcomed public comments on our proposal to remove the TOB2/2a measure from the IPFQR Program.
We received the following comments on our proposal.
Comment: Many commenters supported our proposal to remove the Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment TOB2/2a measure. Some of these commenters agreed with our rationale that the costs of this measure outweigh the benefits of its continued use in the IPFQR Program. Several commenters recommended removing the measure immediately, rather than beginning with FY 2024 payment determination as proposed, to further reduce burden. One commenter agreed that providers will continue offering this intervention even if it is not being measured. Another commenter further expressed that removal is appropriate because the measure is no longer NQF endorsed and is not specified for this setting.
Response: We thank the commenters for their support. 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 to remove the measure following that payment determination, that is, for the FY 2024
payment determination. While we continue to believe that the performance on the TOB2/2a measure in recent years indicates that IPFs routinely offer
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tobacco use cessation interventions during the inpatient stay, we recognize that we will not be able to monitor whether IPFs continue these interventions if we remove this measure. The commenter is correct that the measure is no longer NQF endorsed and is not specified 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 and we continue to believe that this measure is appropriate for the IPF setting.
Comment: One commenter expressed the belief that progress in electronic reporting systems leads to lower burden for reporting this measure. This commenter expressed the belief that this reduced burden should factor into the consideration of whether costs outweigh benefits and recommended that CMS
retain this measure.
Response: We thank the commenter for this feedback. However, we note that because this is a chart-abstracted measure, we do not believe access to electronic reporting systems will significantly impact the burden of collecting and reporting this measure for most IPFs.
Comment: One commenter supported removal of the Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment Provided TOB2/2a measure, but recommended development of more meaningful measures than TOB2/2a and Tobacco Use Treatment Provided or Offered at Discharge and Tobacco Use Treatment Provided at Discharge TOB3/3a to address screening and intervention for tobacco use. One commenter recommended that CMS seek consumer input on the benefit of measures before proposing to remove them.
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 tobacco use 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 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
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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 TOB2/2a measure from the IPFQR
Program measure set. Some of these commenters expressed that there continues to be significant room for improvement in providing interventions. One commenter specifically observed that the measure is not topped out. A few commenters observed that the proposed removal is poorly timed due to the increase in tobacco use during the COVID19
pandemic. Another commenter cited evidence supporting the benefit of brief interventions as part of a comprehensive program to address topped out.
We agree with commenters that not all facilities perform uniformly well on the Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment Provided TOB2/2a measure. We also agree with the commenters observation that tobacco use has increased during the COVID19 pandemic.160 In our literature review, we also identified evidence that individuals who use tobacco may be at an increased risk of COVID19 complications and tobacco use treatment may help mitigate these complications.161 To ensure that providers would continue to address tobacco use among this patient population, we maintained the Tobacco Use Treatment Provided or Offered at Discharge and Tobacco Use Treatment Provided at Discharge TOB3/3a.
However, we agree with the commenter who expressed that these interventions are most effective as part of a comprehensive tobacco treatment program. Given the increased need for tobacco use interventions due to the COVID19 pandemic, that this measure is not topped out and there is room for improvement across facilities,162 and the importance of providing tobacco use treatment during the inpatient stay to improve the efficacy of tobacco use treatment at discharge, we believe that the benefits of retaining the Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment Provided TOB
2/2a measure are greater than we 160 Giovenco et. al., Multi-level drivers of tobacco use and purchasing behaviors during COVID19
lockdown: A qualitative study in the United States, International Journal of Drug Policy, Volume 94, August 2021, 103175.
161 https www.who.int/news/item/11-05-2020who-statement-tobacco-use-and-covid-19.
162 For the FY 2018 payment determination, the mean performance nationally was approximately 79
percent of patients who screened positive for tobacco use were provided or offered treatment while inpatients.

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