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CMS-1403-FC
quality measures results and/or numerator and denominator
data on quality measures.
Comment: Two commenters requested that we specify what
constituted an acceptable validation strategy for
registries.
Response: As a result of the MMSEA, which was enacted
in December, 2007, and modified the PQRI, we implemented
registry-based submission for the 2008 PQRI. Thus, for
2008, we required registry vendors to supply CMS with their
validation strategy that would detail how the registry
would ensure that the data the registry reported to CMS was
accurate. We found that there are several variations for
this process that registries use. We do not believe we
have enough experience with registries to specify a single
validation strategy that all should employ and we believe
we are benefited from allowing a variety of such techniques
to be employed based on our approval at this point.
Therefore, for the 2009 PQRI, registry vendors will again
be required to supply us with their validation strategy
that details how the registry would ensure that the data
the registry reports to us is accurate. In addition, we
note that registries are required to sign an attestation
statement to CMS vouching for the accuracy of the data that
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