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

could support development in time for inclusion in the 2008<br />

PQRI. As the contracted measure developer, QIP was<br />

responsible for supporting the measures through the AQA<br />

adoption process. <strong>CMS</strong> funded a project with the NQF which<br />

reviewed the measures for endorsement.<br />

We plan to continue working to fill gaps in available<br />

consensus endorsed or adopted measures consistent with<br />

available time and resources. However, we largely depend<br />

on and encourage the development of measures by<br />

professional organizations and other measure developers.<br />

Ideally, in the future, there will be a sufficient number<br />

of clinician-level quality measures that meet the statutory<br />

requirements that <strong>CMS</strong> would be able to just select PQRI<br />

measures from these existing measures rather than needing<br />

to fund the development of additional clinician-level<br />

quality measures.<br />

Regarding the concerns cited by therapists unable to<br />

participate in PQRI since they do not use the 1500 or 837-P<br />

claim form, we note as we did in the CY 2008 PFS final rule<br />

with comment period (73 FR 66337) that our analysis of<br />

claims-based alternatives to enable participation<br />

determined that extensive modifications to the claims<br />

processing systems of <strong>CMS</strong> and providers would be required.<br />

Such modifications would represent a material<br />

540

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