To: Administrator Seema Verma
"We support a parsimonious inventory of meaningful, robust measures in the program and are committed to assisting CMS in developing and maintaining this inventory but are concerned that CMS is not applying consistent standards and rationales for selecting and removing measures. CMS specifically states that it is interested in outcome measures and as part of its annual review considers “whether the measure removal will result in no remaining outcome or high priority measures available to a specialty to meet the quality performance category reporting requirements.” However, CMS has removed several outcome and intermediate outcome measures."
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