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

be representative of an eligible professional’s patient<br />

population. That is, 80 percent is a sufficiently large<br />

reporting rate that the performance rates calculated from<br />

the 80 percent sample are substantially the same as the<br />

performance rates calculated from 100 percent of applicable<br />

cases. Although a 100 percent sample of cases for which<br />

individual quality measures or measures group are<br />

applicable would eliminate any sampling error, requiring<br />

100 percent reporting of applicable cases would cause<br />

eligible professionals to be ineligible for an incentive<br />

payment based on a failure to report data on a single<br />

missed case that falls into the quality measure’s<br />

denominator.<br />

Additionally, the 80 percent reporting criteria for<br />

individual quality measures is statutorily required through<br />

2009 for individual quality measures reported through<br />

claims. While the Secretary is authorized to establish a<br />

different reporting threshold for measures groups and<br />

registry-based reporting, we believe that it is necessary<br />

and desirable to maintain consistency and to achieve a<br />

balance amongst the reporting options in order to promote a<br />

successful program.<br />

With respect to requiring a minimum number of Medicare<br />

Part B FFS patients in the sample for registry-based<br />

560

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