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

Comment: We received many comments in favor of<br />

accepting quality measures data through EHRs in 2009.<br />

These commenters cited EHRs as a means for increasing PQRI<br />

participation and being able to report more accurate data.<br />

There were a few commenters who, while favoring EHR data<br />

submission in general, thought that it was premature to<br />

begin this process in 2009.<br />

Response: We proposed to begin EHR data submission for<br />

PQRI in 2009 based on anticipation that we would have<br />

sufficient testing completed to be confident that systems<br />

would be in place and operational by January 1, 2009. At<br />

this point, the testing process is incomplete. As a<br />

result, we agree with the commenter’s suggestion that it is<br />

premature to begin EHR submission as part of the 2009 PQRI.<br />

Rather, we believe that it is more prudent to allow the<br />

2008 testing process to be completed.<br />

Furthermore, we are aware of the importance of<br />

promoting and aligning with the work of health information<br />

technology (HIT) standards development organizations. By<br />

postponing implementation of EHR submissions for PQRI, we<br />

believe this alignment with and promotion of the adoption<br />

and uses of HIT standards will be enhanced.<br />

Finally, we believe it would benefit eligible<br />

professionals to know in advance of the start of a PQRI<br />

585

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