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NAQC Newsroom: Announcements

Deadline of June 26: Submit Comments on the Centers for Medicare and Medicaid Services Proposed Rule

Thursday, June 14, 2018  
Posted by: Natalia Gromov

Every year, the Centers for Medicare and Medicaid Services (CMS) updates the “Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting” rules. On May 8, 2018, CMS proposed the new rules for next year. The proposed rule would remove two of the tobacco use measures that are currently required. The two measures are: TOB -1 (Tobacco Use Screening) and TOB-3 (Tobacco Use Treatment Provided or Offered at Discharge and Tobacco Use Treatment at Discharge).

CMS is currently accepting comments on their proposed rule. The proposal and submission instructions may be viewed here: 

Below are discussion points that could be developed into comments and submitted to CMS by June 26, 2018.

Discussion Points:

·          Individuals with serious phycological distress smoke at higher rate (35.8 percent) than those without serious phycological distress (14.7).[i]

·          Only 48.9 percent of mental health treatment facilities reported screening patients for tobacco use and only 64 percent of substance abuse treatment facilities reporting screening patients for tobacco use. (More information can be found here).[ii]

·          CMS is proposing to remove TOB-1/ NQF #1651 (Tobacco Use Screening Measure) because its performance is so high and unvarying that any improvement can no longer be made. However, other sources report lower rates of tobacco screening for similar populations. There is concern that the progress will be lost without the required quality measure.

·          CMS is proposing to remove TOB-3 and TOB-3a/ NQF #1656 because they believe the burden on providers is too great and that this measure is duplicative of NQF #0647.

·          The NQF #0647 measure is not sufficient to replace the TOB-3 and TOB-3a because it is not specifically ask about tobacco use treatment. More information on the NQF #0647 can be found here

·          REQUESTED ASK: Do not remove the TOB-1 and TOB-3/ TOB-3a measures from the Inpatient Psychiatric Facilities Prospective Payment System and Quality Reporting Rule for FY 2019.


[i] Jamal A, Phillips E, Gentzke AS, et al. Current Cigarette Smoking Among Adults — United States, 2016. MMWR Morb Mortal Wkly Rep 2018;67:53–59. DOI:

[ii] Marynak K, VanFrank B, Tetlow S, et al. Tobacco Cessation Interventions and Smoke-Free Policies in Mental Health and Substance Abuse Treatment Facilities — United States, 2016. MMWR Morb Mortal Wkly Rep 2018;67:519–523. DOI:

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