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CMS-1403-FC on the CMS Web site at http://www.cms.hhs.gov/QualityInitiativesGenInfo/downloads/ QualityMeasuresDevelopmentOverview.pdf. Eligible professionals also have the opportunity to provide input on a measure as the measure is being vetted through the consensus endorsement and/or adoption process. Both the NQF and AQA employ a public comment period for measures vetted through their respective consensus endorsement or adoption processes. Finally, eligible professionals have an opportunity to provide input on measures selected for inclusion in PQRI through the notice and comment rulemaking process we use to announce the measures selected for inclusion in PQRI each year. As required by section 1848(k)(2)(B)(ii) of the Act, we proposed measures for the 2009 PQRI in the Federal Register in July, which was followed by a 60-day comment period in which eligible professionals had the opportunity to comment. Accordingly, we believe the additional requirement under MIPPA with regard to the 2009 PQRI has been met in multiple ways. ii. Summary of Comments and Responses We received several comments related to the statutory requirements for measures included in the 2009 PQRI and/or our approach to the selection of measures, which are summarized and addressed below. 596
CMS-1403-FC Comment: Several comments expressed concerns about the AQA’s structure and original intended purpose not being ideally suited to its current role in PQRI, and its role in the measure endorsement process not clearly adding value to the process. Many comments noted that the AQA does not meet the NTTAA definition of a “voluntary consensus standards body.” Response: Both the NQF and the AQA were identified as examples of consensus organizations under section 1848(k)(2)(B)(i) of the Act. We interpreted this to mean that for purposes of the PQRI, these organizations, as constituted on the date of enactment of the MIEA-THRCA authorizing legislation, are considered to be consensus organizations. On the other hand we stated that we found the NQF to be an organization organized and operating in a manner that meets the NTTAA definition of a “voluntary consensus standards body,” but we did not find that the AQA constituted such an organization. We also stated our policy preference for measures endorsed by an organization that meets the NTTAA definition of “voluntary consensus standards body” to one that does not so qualify. Further, we stated our policy that a measure that was specifically declined for endorsement by the NQF would not be included in PQRI even though it was adopted by AQA. 597
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<strong>CMS</strong>-1403-FC<br />
Comment: Several comments expressed concerns about<br />
the AQA’s structure and original intended purpose not being<br />
ideally suited to its current role in PQRI, and its role in<br />
the measure endorsement process not clearly adding value to<br />
the process. Many comments noted that the AQA does not<br />
meet the NTTAA definition of a “voluntary consensus<br />
standards body.”<br />
Response: Both the NQF and the AQA were identified as<br />
examples of consensus organizations under section<br />
1848(k)(2)(B)(i) of the Act. We interpreted this to mean<br />
that for purposes of the PQRI, these organizations, as<br />
constituted on the date of enactment of the MIEA-THRCA<br />
authorizing legislation, are considered to be consensus<br />
organizations. On the other hand we stated that we found<br />
the NQF to be an organization organized and operating in a<br />
manner that meets the NTTAA definition of a “voluntary<br />
consensus standards body,” but we did not find that the AQA<br />
constituted such an organization. We also stated our<br />
policy preference for measures endorsed by an organization<br />
that meets the NTTAA definition of “voluntary consensus<br />
standards body” to one that does not so qualify. Further,<br />
we stated our policy that a measure that was specifically<br />
declined for endorsement by the NQF would not be included<br />
in PQRI even though it was adopted by AQA.<br />
597