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

● <strong>CMS</strong> may want to consider reporting data at the<br />

physician group or team level as opposed to the individual<br />

level as well as consider reporting composite measures<br />

rather than individual measures.<br />

● Eligible professionals should have the ability to<br />

opt-out of having their information made public.<br />

● Public reporting of PQRI measurement results should<br />

be limited to those measures that have achieved an agreed<br />

upon baseline of scientific acceptability post-<br />

implementation or to those measures on which eligible<br />

professionals chose to submit data.<br />

● <strong>CMS</strong> should publish the names of participating<br />

eligible professionals only in cases where the PQRI<br />

measures that the eligible professionals reported on <strong>has</strong><br />

<strong>been</strong> in use in the PQRI for at least 3 years. <strong>This</strong><br />

indicates at least some measure stability in the program<br />

and allows <strong>CMS</strong> to recognize those eligible professionals<br />

that reported on measures that have <strong>been</strong> in use in PQRI for<br />

less than 3 years as early adopters.<br />

● Any Physician Compare tool developed by <strong>CMS</strong> needs<br />

to be user-friendly and thoroughly vetted and evaluated<br />

prior to going to live to the public. <strong>CMS</strong> should consider<br />

formats that balance the needs of end users with the amount<br />

of data to be displayed and permit specific action by<br />

668

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