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

● Not clear how information on an individual’s<br />

participation in the PQRI would be helpful or meaningful;<br />

● The analysis of physician performance on some<br />

measures will be based on small numbers;<br />

● <strong>CMS</strong>’ data on PQRI participation may be an<br />

inaccurate representation of the number of eligible<br />

professionals participating or making a good faith effort<br />

to participate in PQRI since clearinghouses inappropriately<br />

removed NPI information from claims submissions;<br />

● Major improvements are needed to the Physician and<br />

Other Healthcare Professional Directory before it can form<br />

the basis for a Physician Compare Web site because there<br />

are accuracy issues associated with the data on the<br />

Physician and Other Healthcare Professional Directory;<br />

● It would be unfair to eligible professionals to<br />

publish PQRI information since no interim feedback reports<br />

are provided to help participants determine if they are<br />

reporting correctly;<br />

● It would be especially unfair to publicly report<br />

2007 and 2008 data because eligible professionals were not<br />

informed in advance that such information would be publicly<br />

reported;<br />

● Publicly reporting 2007 PQRI participation<br />

information may be perceived by physicians as reneging on<br />

662

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