DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for ...

CMS-1503-FC 1098
Comment: We received several comments in support of the proposal to decrease
the reporting sample from 80 percent to 50 percent of applicable cases where the
measures are reportable as this would encourage greater Physician Quality Reporting
System participation. One commenter expressed support for the lower percentage due to
the errors and complexity seen to date with claims-based reporting in the Physician
Quality Reporting System. Other commenters noted that a less restrictive requirement is
a step forward in decreasing the costs and burdens associated with Physician Quality
Reporting System participation.
Response: We appreciate the commenters' positive feedback. In lowering the
reporting threshold for claims-based reporting from 80 percent to 50 percent, we are, as
indicated by a commenter, acknowledging the complexity of claims-based reporting. As
stated in the CY 2011 PFS proposed rule (75 FR 40176), a major reason that eligible
professionals who participate in the Physician Quality Reporting System via claims-based
reporting fail to do so satisfactorily is that they fail to report at the required 80 percent.
As shown in the quarterly QDC Error Reports that we post on the CMS Physician Quality
Reporting System website at http:www.cms.gov/PQRI , eligible professionals often do
not report QDCs on claims that are eligible for inclusion in a measure's denominator or
report QDCs on claims that are not eligible for inclusion in a measure's denominator.
When an eligible professional fails to report QDCs on eligible cases, it negatively
impacts their reporting rate for that measure or measures group. When an eligible
professional reports QDCs on ineligible cases, it neither improves nor negatively impacts
their reporting rate for that measure or measures group. Thus, while lowering the
reporting threshold may decrease the number of cases on which an eligible professional is