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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations reporting on COVID19 vaccination coverage among HCP are sufficient to outweigh this burden. In addition, commenters are correct in noting that when we removed the Influenza Vaccination Coverage Among Healthcare Personnel NQF 0431
measure from the IPFQR Program in the FY 2019 IPF PPS final rule, we observed that reporting measure data through the NHSN is relatively more burdensome for IPFs than for acute care hospitals and that this may be especially true for independent or freestanding IPFs 83 FR
38593 through 38595. However, in our analysis of facilities that did not receive full payment updates for FY 2018 and FY 2019 and the reasons these facilities did not receive full payment updates we observed that 98.24 percent and 99.05
percent of IPFs respectively, including small, independent, and freestanding IPFs, successfully reported data for the Influenza Vaccination Coverage Among Health Care Personnel NQF 0431
measure prior to its removal from the IPFQR Program. For the reasons outlined above, the COVID19
pandemic and associated PHE has had a much more significant effect on most aspects of society, including the ability of the healthcare system to operate smoothly, than influenza, making the benefits of the COVID19 Vaccination Among HCP measure greater than those of the Influenza Vaccination Coverage Among Health Care Personnel NQF
0431 measure.
Comment: Other commenters expressed concern that facilities face duplicative reporting requirements given that other agencies are requiring reporting through systems other than NHSN, such as the HHS TeleTracking site. A few of these commenters recommended that CMS use the TeleTracking site for data reporting and consumer information as opposed to adopting a quality measure. Other commenters recommended that CMS
sunset TeleTracking and use NHSN for reporting COVID19 vaccination coverage data. One commenter recommended that CMS collaborate with CDC to ensure minimal reporting burden.
Response: We recognize that this measure may lead to duplicative reporting requirements if facilities voluntarily report COVID19 HCP
vaccination information to data reporting systems other than NHSN, and we are collaborating with other HHS
agencies, including the CDC, to ensure minimal reporting burden and to eliminate duplicative requirements to the extent feasible.
Comment: Some commenters expressed concern about the measure
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specifications leading to increased reporting burden. Several of these commenters expressed that the proposed quarterly reporting of three weeks of data one week per month is excessively burdensome. Other commenters expressed concern that the measure specifications are not aligned with the Influenza Vaccination Coverage Among Healthcare Personnel measure NQF 0431, specifically noting that the COVID Vaccination Coverage Among HCP measure requires data elements such as contraindications that are not required for Influenza Vaccination Coverage Among Healthcare Personnel measure NQF
0431. One commenter observed that including all staff not just clinical staff or staff directly employed by the IPF
makes the measure unduly burdensome.
Another commenter observed that tracking location is challenging in large organizations with staff that work across locations.
Response: We recognize commenters concern regarding reporting burden associated with the specifications of this measure. We believe that, given the public health importance of vaccination in addressing the COVID19 PHE, the benefits of requiring reporting outweigh the burden. We believe that reporting these data on a frequent interval would increase their value by allowing the CDC to better track these important public health data while also being a valuable quality measure that supports consumer choice and IPF improvement initiatives. Because the CDC requests data reported on a monthly basis for one week per month, we believe this is an appropriate reporting frequency for our quality measure to ensure that IPFs do not have duplicative reporting requirements to meet the CDCs need for public health data and CMS quality measure reporting requirements. We further note that while we have sought to align this measure with the Influenza Vaccination Coverage Among HCP
measure NQF 0431, each measure addresses different public health initiatives and therefore complete alignment may not be possible. For example, because influenza vaccinations are provided during the influenza season that is, October 1
through March 31 these measures have different reporting periods.
Further, we note that while the Influenza Vaccination Coverage Among HCP measure NQF 0431 does not have a denominator exclusion for HCP
with contraindications to the influenza vaccine, there is a numerator category for these HCP. Specifically, the numerator description is as follows:
HCP in the denominator population
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who during the time from October 1 or when the vaccine became available through March 31 of the following year:
. . . b were determined to have a medical contraindication/condition of severe allergic reaction to eggs or to other components of the vaccine, or a history of Guillain-Barre Syndrome within 6 weeks after a previous influenza vaccination . . . 115 We believe that this numerator element requires the IPF to track HCPs contraindications to the influenza vaccination. Therefore, we disagree with the commenters statement that the COVID19 Vaccination Coverage Among HCP measure is more burdensome than the Influenza Vaccination Coverage Among HCP
measure due to requiring IPFs to track HCPs contraindications to the vaccine.
Finally, we note that CDCs guidance for entering data requires submission of HCP count at the IPF level 116 and the measure requires reporting consistent with that guidance. We proposed the reporting schedule of monthly reporting of data from only one week a month to provide COVID19 vaccination coverage data on a more timely basis than annual influenza vaccination coverage NQF
0431 while also reducing burden on facilities of weekly reporting which has been the reporting cycle for many COVID19-related metrics during the pandemic. As described in response to previous commenters, we believe that the public health benefits to having these data available are high, and that they therefore outweigh the burden of reporting for systems with multiple facilities or locations. In summary, we recognize that there may be some elements of the measure specifications that increase burden for some IPFs, however given the impact that the COVID19 PHE has had on society and the healthcare system, we believe that the benefits outweigh this reporting burden.
Comment: Some commenters expressed concern that having some vaccinations require two doses creates undue reporting burden for IPFs. One commenter recommended modelling this measure on the measure under consideration for patient vaccination coverage within the Merit-Based Incentive Payment System MIPS
program which would require reporting based on receipt of one dose, as opposed to requiring reporting on receipt of a full course of the vaccine. Some commenters 115 http www.qualityforum.org/Projects/n-r/
Population_Health_Prevention/0431_
InfluenzaImmunizationHCPersonnelForm_
CDC.aspx.
116 COVID19 Vaccination Non-LTC Healthcare Personnel TOI cdc.gov.

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