PUBLIC SUBMISSION | As of: June 22, 2010 Received: June 18, 2010 Status: Draft Category: Health Care Industry - PI015 Tracking No. 80b04f39 Comments Due: June 18, 2010 Submission Type: Web |
Docket: CMS-2010-0177
Medicare Part C and Part D Data Validation (42 C.F.R. §422.516g and §423.514g) - (CMS-10305)
Comment On: CMS-2010-0177-0001
Medicare Part C and Part D Data Validation (42 C.F.R. §422.516g and §423.514g): CMS-10305
Document: CMS-2010-0177-DRAFT-0020
MI
Grand Rapids, MI, 49525
The sampling method appears to be a bit ambiguous. For example, if you sample from the denominator for procedure frequency or SRAE, and you only select 205 members, it is unlikely that your sample will include any of the members for which there was a positive match. However, if you sample from the numerator, then it’s both not a random sample and you would have to have an very large plan and/or very poorly performing hospitals in your network to even approach a number from which 205 could be sampled.
Although the documentation asks for “programming code”, it seems more appropriate to provide pseudo code (i.e. programming code translated into understandable English).
File exchange using encrypted CD seems both archaic and less secure. We suggest using other means (for example, we use a secure web server for most PHI transmissions) as the primary method of file exchange.