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CMS-1403-FC clarification on which 30 patients should be included in the consecutive patient sample. Response: We are pleased that many commenters found the 30 consecutive patient reporting option to be useful and were supportive of this option. We agree that a sample of 30 consecutive patients would be a nonrandom sample, but it is our intention to allow physicians and other eligible professionals greater flexibility and opportunities to participate in PQRI. In addition, requiring consecutive patients would prevent eligible professionals from being able to selectively report cases to enhance their performance rates. While we do not have the results of the 2008 PQRI reporting, we believe that a minimum sample size of 30 consecutive patients is sufficient to calculate comparable performance rates across eligible professionals furnishing comparable services. Patient sample sizes of 30 are commonly considered to be a reasonable minimum threshold for being able to reliably report health care performance measurement results. Results from our Better Quality Information for Medicare Beneficiaries (BQI) pilot project indicate that minimum patient sample sizes of between 30 through 50 patients per physician are needed to make reliable distinctions between physicians’ performance. 556

CMS-1403-FC (Delmarva Foundation for Medical Care. Enhancing Physician Quality Performance Measurement and Reporting Through Data Aggregation: The BQI Project. October 2008.) We expect additional experience with PQRI reporting to clarify optimal sample sizes and reporting criteria for use in future reporting periods. We will continually evaluate our policies on sampling and notify the public through future notice and comment rulemaking if we make substantive changes. As we evaluate our policies, we plan to continue a dialogue with stakeholders to discuss opportunities for program efficiency and flexibility. As described in Table 12, for claims-based reporting of measures groups, eligible professionals wishing to report data on measures groups using the consecutive patient criteria should include only Medicare Part B FFS patients in the consecutive patient sample. For registry- based reporting of measures groups, eligible professionals wishing to report data on measures groups using the consecutive patient criteria may include some non-Medicare FFS patients. However, there must be more than one Medicare Part B FFS patient included in this patient sample as well. Comment: We received a large volume of comments in support of discontinuing the 15 consecutive patients for a 557

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

clarification on which 30 patients should be included in<br />

the consecutive patient sample.<br />

Response: We are pleased that many commenters found<br />

the 30 consecutive patient reporting option to be useful<br />

and were supportive of this option. We agree that a sample<br />

of 30 consecutive patients would be a nonrandom sample, but<br />

it is our intention to allow physicians and other eligible<br />

professionals greater flexibility and opportunities to<br />

participate in PQRI. In addition, requiring consecutive<br />

patients would prevent eligible professionals from being<br />

able to selectively report cases to enhance their<br />

performance rates.<br />

While we do not have the results of the 2008 PQRI<br />

reporting, we believe that a minimum sample size of 30<br />

consecutive patients is sufficient to calculate comparable<br />

performance rates across eligible professionals furnishing<br />

comparable services. Patient sample sizes of 30 are<br />

commonly considered to be a reasonable minimum threshold<br />

for being able to reliably report health care performance<br />

measurement results. Results from our Better Quality<br />

Information for Medicare Beneficiaries (BQI) pilot project<br />

indicate that minimum patient sample sizes of between 30<br />

through 50 patients per physician are needed to make<br />

reliable distinctions between physicians’ performance.<br />

556

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