Notice: This CMS-approved document has been submitted - Philips ...

CMS-1403-FC
the AMA–PCPI should be the sole source for physician level
measures. Several commenters specifically presented an
interpretation of the requirement under section
1848(k)(2)(B)(i) of the Act for the 2009 PQRI measures to
include measures submitted by a physician specialty as
meaning that the 2009 PQRI should include only measures
developed by physician organizations, to assure physician
control of available measures applicable to assessing the
clinical performance of individual physicians.
Response: Physician involvement and leadership is
standard in the work of both measure developers and
consensus organizations. As a result, physicians are
actively involved at all levels of measure development and
consensus adoption and endorsement. We are in agreement
that physician expertise is an important ingredient in
measure development and in the consensus process. We
further recognize the leadership of physician
organizations, as is reflected in the large number of
physician quality measures included in PQRI which were
developed by the AMA–PCPI and its participating specialty
societies.
However, we do not agree that physicians should be in
complete control of the process of measure development, as
would be the case if measures were required to be developed
599