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CMS-1403-FC
important difference in that approach to PQRI is that under
PQRI, by submitting quality data, the eligible professional
indicates that the patient is appropriately attributed to
that professional. When purely administrative data are
used, attribution rules would need to be applied, with
which the physician or other eligible professional may not
agree. Thus, focusing on administrative-data based
measures only could have the unintended consequence of
holding the eligible professional responsible for certain
services which the eligible professional might feel are
beyond their scope of care for a particular patient.
Comment: Several commenters recommended changes to
specific quality measures’ titles, definitions, and
detailed specifications or coding. Many of these
recommendations were based on alternative interpretations
of clinical evidence or concerns about the utility of the
measures. Some requests were specifically concerned that
measures be expanded to include specific professionals to
whom the measure may be applicable such as occupational
therapists, registered dieticians, and audiologists.
Specifically, one commenter suggested that in order to
maximize the impact of Measure #1 Diabetes Mellitus:
Hemoglobin A1c Poor Control in Diabetes Mellitus, the PQRI
specifications should continue to require a performance
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