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CMS-1503-FC 756<br />

http://www.cms.gov/InfoExchange/03_listserv.asp#TopOfPage. Given the relatively fast<br />

timeline described in section 1862(l) of the Act, we do not believe it is feasible to add a<br />

requirement <strong>for</strong> publication of a notice in the Federal Register whenever an NCD is<br />

opened. There<strong>for</strong>e, we are not adopting the public comment. Please note that we do<br />

publish a listing in the Federal Register of all NCDs that are issued. This in<strong>for</strong>mation is<br />

included in the quarterly notice issued pursuant to section1871(c) of the Act.<br />

Comment: Several commenters noted that we did not include the health risk<br />

assessment (HRA) in our proposal that section 4103 of the ACA ultimately requires to be<br />

part of the AWV. Several of these commenters strongly supported the CMS approach of<br />

not immediately implementing the HRA requirement on January 1, 2011. Some<br />

commenters noted that a separate ACA provision also concerns the establishment of an<br />

HRA, but used later deadlines. Specifically, section 1861(hhh)(4)(A) of the Act requires<br />

consultation to develop publically available guidelines <strong>for</strong> HRAs by March 23, 2011.<br />

One commenter noted that "the relative recent enactment of the Af<strong>for</strong>dable Care Act<br />

provided CMS little time to establish standard processes related to a health risk<br />

assessment (HRA)." Another commenter stressed the need <strong>for</strong> a standardized HRA<br />

model or models that is/are recognized and accepted nationally. Another commenter<br />

urged us to act as expeditiously as possible in a consultative way by directly engaging the<br />

major medical organizations and stakeholders who represent physicians and other<br />

clinicians who see Medicare beneficiaries. One commenter recommended that the "HRA<br />

program should also be pilot-tested be<strong>for</strong>e widely imposed to determine such critical<br />

factors as the effectiveness of the guidelines and the administrative burden imposed on<br />

the physicians."

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