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DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for ...

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CMS-1503-FC 1466<br />

groups may need more time <strong>for</strong> data submission since they would be required to report<br />

more measures and presumably have a larger patient population.<br />

In addition to costs incurred by eligible professionals and group practices,<br />

registries and EHR vendors may also incur some costs related to the Physician Quality<br />

Reporting System. Registries interested in becoming "qualified" to submit on behalf of<br />

individual eligible professionals would also have to incur a cost associated with the<br />

vetting process and with calculating quality measures results from the data submitted to<br />

the registry by its participants and submitting the quality measures results and numerator<br />

and denominator data on quality measures to CMS on behalf of their participants. We<br />

estimate the registry self-nomination process will cost approximately $500 per registry<br />

($50 per hour x 10 hours per registry). This cost estimate includes the cost of submitting<br />

the self-nomination letter to CMS and completing the CMS vetting process. Our estimate<br />

of $50 per hour average labor cost <strong>for</strong> registries is based on the assumption that registry<br />

staff include IT professionals whose average hourly rates range from $36 to $84 per hour<br />

depending on experience, with an average rate of nearly $50 per hour <strong>for</strong> a mid-level<br />

programmer. Because we are finalizing new requirements <strong>for</strong> 2011, the 2010 qualified<br />

registries will incur similar costs associated with the self-nomination process. We do not<br />

believe that there are any additional costs <strong>for</strong> registries associated with a registry<br />

calculating quality measures results from the data submitted to the registry by its<br />

participants and submitting the quality measures results and numerator and denominator<br />

data on quality measures to CMS on behalf of their participants. We believe that the<br />

majority of registries already per<strong>for</strong>m these functions <strong>for</strong> their participants.

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