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<strong>CMS</strong>-1403-FC<br />

base the incentive payment on RVUs rather than the amount<br />

billed to Medicare.<br />

Response: We do not have the authority to change the<br />

basis for calculation of the incentive payment. Section<br />

1848(m)(1) of the Act, as redesignated and amended by the<br />

MIPPA, authorizes us to make incentive payments for<br />

satisfactorily reporting data on quality measures for<br />

covered professional services furnished by eligible<br />

professionals during the 2009 PQRI reporting period equal<br />

to 2.0 percent of the estimated total allowed charges for<br />

all covered professional services furnished during the<br />

reporting period that are <strong>submitted</strong> no later than 2 months<br />

after the end of the reporting period. However, we are<br />

committed to exploring and supporting practical, effective<br />

mechanisms for quality-of-care data submission that promote<br />

efficiency by streamlining participants’ and our data<br />

collection and handling. As such, and as described below<br />

in this section of the final rule with comment period, we<br />

have developed and are implementing options for registry-<br />

based submission of quality measures data and plan to<br />

implement options for EHR-based submission of quality<br />

measures data after some additional testing.<br />

In addition, we have increased the number of measures<br />

groups and individual PQRI quality measures available for<br />

537

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