Federal Register - August 4, 2021
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Source: Federal Register
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Federal Register / Vol. 86, No. 147 / Wednesday, August 4, 2021 / Rules and Regulations
However, we recognize that such IPFs and health systems would not have access to publicly reported data regarding other IPFs and that these data may be useful for baselining. Therefore, we agree that such IPF level and systemic programs to reduce alcohol use is a benefit to retaining the measure that we had not evaluated in our proposal to remove this measure.
Comment: One commenter observed that this measure is less burdensome than the newly proposed COVID19
vaccination measure and therefore the commenter believes that removing this measure because the costs, especially the information collection burden, outweigh benefits is inconsistent.
Response: We evaluate measures on a case-by-case basis looking at the overall benefits of the measure versus the overall costs of the measure. Therefore, measures are not evaluated based on whether they are more or less burdensome than other measures.
However, we now believe that the benefits of retaining this measure are greater than we had considered in our proposal to remove the measure from the IPFQR Program measure set.
After consideration of the public comments, we now believe that the benefits of retaining this measure, which include the potential for IPFs to continue improving performance on this measure, the importance of substance use interventions due to increased substance use during the COVID19
pandemic, and this measures potential influence on other quality improvement activities related to substance use are greater than we had considered in our proposal to remove the measure from the IPFQR Program measure set.
Accordingly, we are not finalizing our proposal to remove the Alcohol Use
Brief Intervention Provided or Offered and Alcohol Use Brief Intervention SUB2/2a measure beginning with the FY 2024 payment determination. That is, we are retaining the Alcohol Use Disorder Brief Intervention Provided or Offered and Alcohol Use Disorder Brief Intervention Provided SUB2/2a measure in the IPFQR Program measure set.
After consideration of the public comments, we are not finalizing our proposal to remove the Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention SUB2/2a measure beginning with the FY 2024 payment determination. That is, we are retaining the Alcohol Use Disorder Brief Intervention Provided or Offered and Alcohol Use Disorder Brief Intervention Provided SUB2/2a measure in the IPFQR Program measure set.
b. Retention of the Tobacco Use Treatment Provided or Offered and Tobacco Treatment TOB2/2a Measure Beginning With FY 2024 Payment Determination 159
We proposed to remove the Tobacco Use Treatment Provided or Offered TOB2 and Treatment TOB2a, collectively referred to as the TOB2/2a 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 Tobacco Use Treatment Provided or Offered and Tobacco Use Treatment TOB2/2a measure in the FY 2015 IPF PPS final rule 79 FR 45971
through 45972 because we believe it is important to address the common comorbidity of tobacco use among IPF
patients. Like SUB2/2a described in the previous subsection, this measure requires facilities to chart-abstract measure data on a sample of IPF patient records, in accordance with established sampling policies 80 FR 46717 through 46719.
When we introduced the TOB2/2a measure to the IPFQR Program, the benefits of this measure were high, because IPF performance was not consistent and 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
2017 payment determination the first year that TOB2/2a was included in the IPFQR Programs measure set and the FY 2019 payment determination we saw substantial performance improvement on TOB2. However, between the FY
2019 and FY 2020 payment determinations, that improvement has leveled off to consistently high performance, as indicated in Table 4.
These data further show that currently there is little room for improvement in the TOB2 measure, and that the quality improvement benefits from the measure have greatly diminished. We continue to believe that tobacco 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 stated in the proposed rule that we believe that most IPFs routinely offer tobacco use brief interventions, and that IPFs will continue to offer these interventions to patients, regardless of whether the TOB2/2a 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
2015 2017 Payment Determination 2016 2018 Payment Determination 2017 2019 Payment Determination 2018 2020 Payment Determination
63.83
74.72
79.04
79.08
71.5
84
91
95
97
98
99
100
100
100
88
88
Truncated Coefficient of Variation TCV
0.49
0.28
0.22
0.22
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 tobacco use because it
is no longer showing significant improvement in IPF performance that is, in providing or offering tobacco use brief interventions. Furthermore, as we
159 We note that the proposed rule incorrectly referred to this measure as the Tobacco Use Brief
Intervention Provided or Offered and Tobacco Use
Brief Intervention TOB2/2a measure, we have corrected it here and throughout this final rule.
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TABLE 4: Performance Analysis for Tobacco Use Treatment Provided or Offered TOB-2