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ACP does not support QPP measure 109: "Osteoarthritis: Function and Pain Assessment." While this measure represents an important clinical concept for clinicians treating patients with a principle diagnosis of OA, there is insufficient evidence to support an appropriate assessment time interval and the denominator specifications are unclear. Furthermore, the measure should specify utilization of a validated, standardized assessment tool that demonstrates improvements in quality outcomes. While it’s important to assess pain and function in patients with a principle diagnosis of OA, it is burdensome for clinicians to perform this assessment at every visit where OA is not the primary patient complaint. While this measure is appropriately specified to assess the quality performance of clinicians practicing in orthopedic subspecialty areas, it is not an appropriate accountability measure for general internists. Additionally, clinicians may encounter interoperability barriers to data access and embedding data into the information system. Eliminating these barriers will likely improve the feasibility of this measure.