PCRC Applauds Representatives Diana DeGette and Fred Upton for Including Sections 309 and 411 in the Cures 2.0 Act

On December 2, 2021, the Physician Clinical Registry Coalition (“PCRC”) submitted a letter to Representatives Diana DeGette (D-CO) and Fred Upton (R-MI) commending them for including Section 411 in the Cures 2.0 Act, which would ensure that clinician-led clinical data registries have meaningful access to Medicare, Medicaid, and State Children’s Health Insurance Program claims data to better track patient outcomes over time, expand their ability to assess the safety and effectiveness of medical treatments, and provide them with the information necessary to assess the cost-effectiveness of therapies.  This legislation would allow clinician-led clinical data registries to link their outcomes data with claims data in a way that would help ascertain the value of new medical technologies and therapies and assist in the development of effective alternative payment models (“APMs”).

PCRC also applauded Representatives DeGette and Upton for including Section 309 in the Cures 2.0 Act, which seeks to increase the use of real-world evidence and support the use of data from clinical care data repositories and patient registries to fulfill post-approval study requirements for products regulated by the Food and Drug Administration.

Click here to read the full letter.


PCRC Requests Congressional Hearing on the Implementation of MACRA

The Physician Clinical Registry Coalition (“PCRC”) recently wrote to Congress requesting that the House Ways and Means and Energy and Commerce Committees and the Senate Finance and HELP Committees convene an oversight hearing (or hearings) to examine the Centers for Medicare and Medicaid Services’ (“CMS”) implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”) as it relates to Qualified Clinical Data Registries (“QCDRs”) and clinician-led clinical data registries.  MACRA requires the Secretary of Health and Human Services (“Secretary”) to encourage the use of QCDRs for reporting measures under the quality performance category of the Merit-Based Incentive Payment System (“MIPS”) program.  MACRA also directs the Secretary to provide Medicare claims data to QCDRs “for purposes of linking such data with clinical outcomes data and performing risk-adjusted, scientifically valid analyses and research to support quality improvement or patient safety.”  Over recent years, however, CMS has established policies that contravene the language and intent of MACRA, including policies that disincentivize meaningful specialty measures.  Therefore, PCRC urged the aforementioned Committees to hold a hearing (or hearings) to examine CMS’s MACRA policies concerning measure testing, data validation requirements, access to claims data, harmonization, topped out measures, credit/incentivization for clinical data and measure testing participation, cooperative agreements, and the MIPS Value Pathway program.

Click here to read the letter to the House Ways and Means and Energy and Commerce Committees.

Click here to read the letter to the Senate Finance and HELP Committees.


PCRC Urges Congress to Provide More Meaningful Access to Medicare, Medicaid, and SCHIP Claims Data

In response to the released discussion draft of the Cures 2.0 legislation, the Physician Clinical Registry Coalition (“PCRC”) submitted a letter to Representatives Diana DeGette (D-CO) and Fred Upton (R-MI) on July 9, 2021, offering recommendations for legislative reform to include in the Cures 2.0 package.  Specifically, PCRC requested that Cures 2.0 include language guaranteeing clinician-led clinical data registries access to Medicare, Medicaid, and State Children’s Health Insurance Program (“SCHIP”) claims data for quality improvement, patient safety, and research purposes.  Such reforms would allow clinician-led clinical data registries to link their outcomes data with the Centers for Medicare and Medicaid Services’ (“CMS’s”) claims data in a way that would assist in the development of effective alternative payment models and provide a greater understanding of the real-world impact of new medical technologies and therapies across numerous patient populations.  PCRC looks forward to working with Representatives DeGette and Upton to ensure that clinician-led clinical data registries have a meaningful way to gain continuous access to Medicare, Medicaid, and SCHIP claims data.

Click here to read the full letter.


PCRC Comments on the Proposed CY 2021 Updates to the Qualify Payment Program

On October 5, 2020, the Physician Clinical Registry Coalition (“PCRC”) submitted comments on the proposed CY 2021 updates to the Quality Payment Program related to Qualified Clinical Data Registries (“QCDRs”) and Qualified Registries (“QRs”).  PCRC expressed concerns regarding the Centers for Medicare and Medicaid Services’ (“CMS’s”) proposals on data validation and QCDR measure testing.  PCRC believes that these proposals would significantly and unreasonably burden QCDRs, QRs, and physicians participating in the Merit-based Incentive Payment System (“MIPS”) program.  PCRC urged CMS to reconsider provisions of the proposed rule that are inconsistent with the agency’s mandate to develop policies that encourage, not inhibit, the use of QCDRs for MIPS reporting.

Click here to read the full letter.


PCRC Responds to Request for Feedback on Cures 2.0 Concept Paper

On June 23, 2020, the Physician Clinical Registry Coalition (“PCRC”) submitted a letter to Representatives Diana DeGette (D-CO) and Fred Upton (R-MI) offering recommendations for legislative reform to include in the Cures 2.0 package.  In response to the published Cures 2.0 concept paper, PCRC requested that Cures 2.0 include language guaranteeing clinician-led clinical data registries access to Medicare claims data for quality improvement, patient safety, and research purposes.  PCRC also urged that Medicare claims data be readily available to clinician-led clinical data registries through the Fast Healthcare Interoperability Resources-based application programming interface and that the Centers for Medicare and Medicaid Services (“CMS”) be required to collect Unique Device Identifiers and share that information with clinician-led clinical data registries.  Such reforms would allow clinician-led clinical data registries to link their outcomes data with CMS claims data in a way that would assist in the development of effective alternative payment models and provide a greater understanding of the real-world impact of new medical technologies and therapies across numerous patient populations.  PCRC looks forward to working with Representatives DeGette and Upton to ensure that clinician-led clinical data registries have a meaningful way to gain continuous access to Medicare claims data.

Click here to read the full letter.


Physician Clinical Registry Coalition Comments on FY 2019 IPIPS NRPM

On June 25, 2018, the Physician Clinical Registry Coalition submitted a comment letter to the Centers for Medicare & Medicaid Services (“CMS”) at the U.S. Department of Health and Human Services expressing our concern about the proposal in the FY 2019 Hospital Inpatient Prospective Payment Systems proposed rule to remove the Public Health and Clinical Data Exchange objective and measures from the Promoting Interoperability Program no later than 2022.

The Coalition strongly urged CMS to retain these measures as a necessary incentive for hospitals and, perhaps more urgently, EHR vendors, to share data electronically with public health entities and clinical data registries.  The Coalition believes these measures help to facilitate and promote the use of Qualified Clinical Data Registries and other clinical outcomes data registries.  The Coalition also expressed its support for comments submitted by the Society of Thoracic Surgeons regarding how CMS can further facilitate price transparency by providing registries with the access to Medicare claims data required by the Medicare Access and CHIP Reauthorization Act of 2015 (“MACRA”).

Click here to read the full letter.


PCRC Submits Letter to HHS Regarding Information Blocking by Electronic Health Record Vendors

On February 8, 2018, the Physician Clinical Registry Coalition submitted a letter to the U.S. Department of Health and Human Services (HHS) expressing our ongoing concerns about information blocking by electronic health record (“EHR”) vendors.

The Coalition strongly advocated for the information blocking language included within the 21st Century Cures Act to prevent EHR vendors from blocking the transmission of clinical outcomes data to third parties, such as clinical data registries. The Cures Act prohibits EHR vendors from interfering with, preventing, or materially discouraging the access, exchange, or use of electronic health information, and grants the HHS Office of the Inspector General (OIG) the authority to investigate and impose penalties upon an EHR vendor that engages in such information blocking. The ability of clinical data registries to access patient information from EHR vendors
is crucial for such registries to achieve their missions of improving quality of care.

Click here to read the full letter.

The Coalition is a group of 25 medical societies and other physician-led organizations that sponsor clinical data registries that collect identifiable patient information for quality improvement and patient safety purposes to help participating providers monitor clinical outcomes among their patients. We are committed to advocating for policies that enable the development of clinical data registries and enhance their ability to improve quality of care through the analysis and reporting of these outcomes.


Common Rule Final Rule Delayed to July 19, 2018

The U.S. Department of Health and Human Services (HHS) released an interim final rule delaying the effective date of the Common Rule final rule to July 19, 2018.  The agencies are working on issuing a proposed rule to further delay the final rule.  This interim final rule does not delay the compliance date for the cooperative research provision, which remains January 20, 2020. The interim final rule can be found here.


PCRC Submits Comments on CY 2018 Updates to Quality Payment Program Final Rule

On January 1, 2018, the Physician Clinical Registry Coalition submitted a comment letter on the CY 2018 Updates to the Quality Payment Program final rule.  The letter emphasizes concerns regarding the lack of transparency and consistency in the QCDR measures review process.  Coalition members experienced the following during the QCDR measure review process for the 2018 performance period: impractical timelines, rejection of measures without regard for clinical rationale, inconsistent feedback and unclear rejection methodology or consolidation rationale, and disjointed communication and review of measures.  The letter requests that CMS does not align QCDR measure approval with the Call for Quality Measures process or create more stringent standards for QCDR measures.  We also asked CMS to grant measures with high performance 7 points in the 2018 performance period and define its policy for placing QCDRs on probation or suspension for data inaccuracies and errors.

Click here to read the full letter.


PCRC Submits Letter Regarding Commercial Use of MIPS Measures

On November 20, 2017, the Physician Clinical Registry Coalition submitted a letter to the Centers for Medicare and Medicaid Services (CMS) outlining its concerns regarding the commercial misuse and licensing of MIPS measures.  The letter discusses the several instances of commercial entity misuses of MIPS measures, such as using measures for profit and not for the purposes of quality improvement, incorrect implementation of measures with clear guidelines, and greater risk for inaccuracies due to lack of operational experience with measure science.

We also asked CMS to extend the requirement that entities that use QCDR or MIPS measures developed by QCDRs must enter into a licensing agreement with the measure owner.  The Coalition believes there is no meaningful distinction between the MIPS and QCDR measures and therefore requests CMS to clarify that MIPS measure developers/owners, including medical societies and clinical data registries, can enforce copyrights, and that third parties wishing to use such measures must enter into licensing agreements with measure owners before they can properly use MIPS measures.

Click here to read the full letter.