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We believe it is important to standardize the lookback period to improve comparability across MRFs by eliminating variances due to different lookback periods, without distorting the data by including data from several years prior that do not account for inflation, efficiencies, or the introduction of new products or services

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[10] Diagnosis is not always straightforward and can be challenging and can take up to several years to receive a diagnosis from the onset of symptoms and almost 60% of those affected are misdiagnosed or not initially diagnosed at all

Response: We thank commenters for their concerns regarding the impact of the proposed update to the Overall Hospital Quality Star Rating methodology for small and rural hospitals