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19.02.2013 Views

CMS-1403-FC Response: We are appreciative of the commenters’ thoughtful and constructive feedback and will take these concerns into consideration as we further develop our plans for publicly reporting PQRI information. While we understand the commenters’ concerns, we note that section 1848(m)(5)(G) of the Act, as added by the MIPPA, requires us to list the names of eligible professionals who satisfactorily submitted PQRI quality measures data in an easily understandable format on our Web site. As such, it is our intent to identify the eligible professionals who satisfactorily submit data on quality measures for the 2009 PQRI on the CMS Web site in 2010. We are not required, nor are we specifically authorized by MIPPA or preceding PQRI authorizing legislation, to publicly report 2007 and 2008 PQRI information submitted prior to July 15, 2008. Comment: A number of the commenters urged CMS to delay the public reporting of information derived from PQRI that was authorized by the MIPPA because eligible professionals should have the opportunity to view their individual data for several years before it is made public. Several commenters provided recommendations for CMS to consider with respect to publicly reporting PQRI information and specifically as we proceed with implementing the MIPPA provision to list the names of the individuals or physician 664

CMS-1403-FC groups who successfully participate in the PQRI on CMS’ Web site. Examples of some of the recommendations received include: ● CMS should educate the public on PQRI and its limitations and include disclaimer language on the Web site explaining the PQRI program and its limitations, such as the program is voluntary, there are many barriers to participation and many valid reasons for nonparticipation, there are many factors that could impact participation, the year to year changes to the program, and PQRI participation status is not a proxy for quality. ● CMS should conduct a formal evaluation to closely review the 2007 and 2008 PQRI program, including the program’s processes and the analysis and validation of the data gathered, before proceeding with public reporting of PQRI participation or performance data. No PQRI data should be publicly released until its accuracy and reliability is verified, otherwise, serious unintended consequences can occur. CMS must make every effort to ensure the accuracy of any information that will be made public, including demographic information and other information listed in the Physician and Other Healthcare Professional Directory, and provide the American Medical Association and medical specialty societies access to 665

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

Response: We are appreciative of the commenters’<br />

thoughtful and constructive feedback and will take these<br />

concerns into consideration as we further develop our plans<br />

for publicly reporting PQRI information. While we<br />

understand the commenters’ concerns, we note that section<br />

1848(m)(5)(G) of the Act, as added by the MIPPA, requires<br />

us to list the names of eligible professionals who<br />

satisfactorily <strong>submitted</strong> PQRI quality measures data in an<br />

easily understandable format on our Web site. As such, it<br />

is our intent to identify the eligible professionals who<br />

satisfactorily submit data on quality measures for the 2009<br />

PQRI on the <strong>CMS</strong> Web site in 2010. We are not required, nor<br />

are we specifically authorized by MIPPA or preceding PQRI<br />

authorizing legislation, to publicly report 2007 and 2008<br />

PQRI information <strong>submitted</strong> prior to July 15, 2008.<br />

Comment: A number of the commenters urged <strong>CMS</strong> to delay<br />

the public reporting of information derived from PQRI that<br />

was authorized by the MIPPA because eligible professionals<br />

should have the opportunity to view their individual data<br />

for several years before it is made public. Several<br />

commenters provided recommendations for <strong>CMS</strong> to consider<br />

with respect to publicly reporting PQRI information and<br />

specifically as we proceed with implementing the MIPPA<br />

provision to list the names of the individuals or physician<br />

664

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