Project:
The Call for Public Comment period begins April 10, 2018 and closes on May 18, 2018 for the Substance Use measures as part of the “Screening, Briefing, Intervention, and Referral to Treatment (SBIRT) Evaluation", contract number HHSS283201200006I, task order HHSS28342004T. The Substance Abuse and Mental Health Services Administration (SAMHSA) has contracted RTI International to beta test the substance use (SUB) measure set. The purpose of the beta test is to obtain more comprehensive information about the acceptability, feasibility, and usability of the SUB measures. As part of this process, we request interested parties to submit comments on the following draft Substance Use eCQMs. The SUB measures are:

• CMS 570 Alcohol Use Screening (SUB-1)
• CMS 574 Alcohol Use Brief Intervention Provided or Offered (SUB-2) /
Alcohol Use Brief Intervention Provided (SUB-2a)
• CMS 575Alcohol and Other Drug Use Disorder Treatment Provided or Offered at Discharge
(SUB-3) / Alcohol and Other Drug Use Disorder Treatment at Discharge (SUB-3a)

Considerations for Review:
The MAT package and human readable of each document is provided for your review and comment. The files are located below in the Attachments section. We seek comments on all components of the SUB Use measures with special attention to following:

SUB 1, SUB 2, SUB 3
In the denominator exclusions, "Physical Exam, Performed" is used to capture cognitive status. Testing participants reported that "Assessment Performed" was used to capture a patient's assessment of cognitive status in their system instead of physical exam.
• What does your site use to capture cognitive status?
What datatype (assessment performed, physical exam, or other) is used at your site to capture an assessment of a patient's cognitive status?
What are the pros and cons about replacing the data type "Physical Exam, Performed" with "Assessment, Performed" for capturing "Cognitive Status"?
• Alpha test participants found the name of the "Cognitive Status" value set confusing. The Cognitive Status value set captures a patients' consciousness, responsiveness and/or mental status of the patient.
• Do you have suggestions for renaming this value set?
What are the pros and cons in renaming this value set to "Neurological Assessment"?

SUB 3
In the measure numerator, the logic currently only includes "Intervention, Order: Moderation of ETOH Consumption Recommendation" and does not include "Intervention, Performed: Moderation of ETOH Consumption Recommendation." Testing participants have requested consideration for adding "Intervention, Performed."

• How does your site capture Moderation of ETOH Consumption Recommendation?
What are the pros and cons about adding "Intervention, Performed"?
• In the measure denominator, the current logic for timing around the "Diagnosis: Alcohol and Drug Dependence" is for any time before the inpatient encounter. For example, a diagnosis from last month, last year, or 10 years ago would satisfy the timing requirement.
• What are pros and cons about the timing parameters for "Diagnosis: Alcohol and Drug Dependence"?
Are there other timing parameters that should be considered?
• Are lab tests for drug/substance use recorded and/or updated in the EHR within a 3-day timeframe of the encounter/episode?
• To gain a better understanding of the medication treatment options offered by your site, please share what treatments are offered.
• What medication treatment options are offered by your site?
What are your thoughts on the medications included in the FDA Approved Medications for Alcohol or Drug Dependence Treatment value set?
Do providers at your site prescribe drugs in this value set?
Are there drugs missing from this value set? If so, please list the names of these drugs?
Does your EHR system's capture a patient's refusal to take a medication?

General:
Please provide your additional thoughts about:
• What is the clinical value and use of the alcohol screening tools used in these measures
• Does your EHR capture the alcohol screening tool score or result?
• Do you agree with the collapsing of risk into the two categories (no/low risk vs. moderate/high risk) defined in the SUB measure specifications? Is your screening tool able to categorize patients into no/low risk or moderate/high risk?
• If you use AUDIT-C, does your EHR capture AUDIT-C data using a structured template?
Would you consider a lab test result for drug intoxication a valid way to screen for alcohol use?
• What are your thoughts about the codes identified in the value sets to capture the data for the measure?
• Are conditions coded with “unspecified” or “uncomplicated” descriptions and if so for what reasons or situations?
• Is excluding patient with Cognitive and Psychiatric Disorders Indicative of Impaired Cognition practical/feasible for these measures?
• Are the referral data elements feasible?
• Is it possible to document that a referral visit was scheduled and attended by the patient or that a medication prescription was filled at the pharmacy?
• Does your facility include 'do not resuscitate orders' in the comfort measures only value set?
• Or is it incorporated Physician order/order set; Narrative note; Advanced directive; Physical exam; None; Other - specify?

Instructions for Posting a Comment:
Do not include personal health information in your comments

1. Navigate to the JIRA ticket PCQM-776 “SUB MEASURE SET CALL FOR PUBLIC COMMENT”.
2. Review description and download measure packages for review.
   • To enter comments, you must have a JIRA account and be logged on.
   • Select “Comment” and enter the following information:
     • The measure(s) you are commenting on:
       • SUB-1 Alcohol Use Screening
       • SUB-2 Alcohol Use Brief Intervention Provided Offered
       • SUB-2a Alcohol Use Brief Intervention Provided
       • SUB-3 Alcohol and Other Drug Use Disorder Treatment Provided or Offered at Discharge
       • SUB-3a Alcohol and Other Drug Use Disorder Treatment at Discharge
       • Substance Use - General
     • Contact name, institution name, email and phone.
     • Your comments, including attachments. You may also include an external hyperlink.
     • Select “Add” to post your comment.
     • You will automatically be added as a watcher of this ticket and receive notifications for all new comments or other changes to the ticket.
     • Select “Unwatch” to stop receiving notifications, but may still be contacted by the ticket originator..

To be considered, comments must be submitted via the JIRA tool by 11:59 p.m. (EST) on May 18, 2018. At the end of the public comment period, all public comments will be posted on the website along with a public comment summary report.
Value Sets are located here:
https://vsac.nlm.nih.gov/welcome
A UMLS license is required. To obtain a license if you do not have one, access:
https://uts.nlm.nih.gov//license.html
Please notify any colleagues who may be interested in commenting on these measures. Thank you!
If you have any questions, please contact AVincent@rti.org.