CMS Releases Display Version of CY 2018 Quality Payment Program final rule

On November 2, 2017, the Centers for Medicare and Medicaid Services (CMS) released the display version of the CY 2018 Quality Payment Program final rule, which will be published in the Federal Register on November 16, 2017.  This final rule sets the requirements for participation in the Quality Payment Program for Year 2 (2018).  In its overview of the final rule, CMS states that it kept many of the flexibilities from the transition year to help clinicians get ready for year 3.  For a summary of the changes between Year 1 and Year 2, please see CMS’s final rule overview here.  Comments on the final rule are due January 1, 2018.


PCRC Submits Comments on the CY 2018 Quality Payment Program

On August 21, 2017, the Physician Clinical Registry Coalition submitted comments on the CY 2018 Quality Payment Program proposed rule to the Centers for Medicare and Medicaid Services (CMS).  In its comments on the proposed rule, the Coalition urged CMS to implement the following changes and clarifications for Year 2 (CY 2018) of the Quality Payment Program:

  1. Create an organized, transparent, and consistent QCDR measures review process and make other adjustments to the QCDR measure review program, such as increase flexibility for review of topped-out measures, delay the timeline for removing non-outcome and outcome measures without a benchmark, increase consultation regarding measure consolidations and approval time for new MIPS measures, and reduce provisional measure approval and limitations associated with the 30 non-MIPS measures cap;
  2. Further simplify the QCDR self-nomination process by increasing the length of QCDR approval to at least two years, improving the tracking of measure ownership, and including all needed information on the self-nomination application;
  3. In the ACI category, allow an eligible clinician to qualify for bonus points for using a specialized or clinical outcomes data registry under active engagement options 1, 2, and 3, and to qualify for full ACI credit when utilizing CEHRT to participate in a clinical data registry;
  4. Clarify that QCDRs and other clinical outcomes data registries should be led and controlled by clinician-led professional organizations or similar entities focused on quality improvement to receive credit under the improvement activities and ACI categories;
  5. Create two separate benchmarks for reporting QCDR measures electronically and manually;
  6. Allow QCDRs and other clinical outcomes data registries the option to assist virtual groups in aggregating measures and activities for reporting.

To view a PDF of the comments, click here.


PCRC Submits Letter Regarding QCDR Measure Review and Application Process

On July 11, 2017, the Physician Clinical Registry Coalition submitted a letter to the Centers For Medicare and Medicaid Services (CMS) outlining its concerns regarding the QCDR measure review and self-nomination process for the 2017 performance year.  Many Coalition members experienced an opaque, disorganized and contradictory review process.  Members experienced frustrations such as inconsistent feedback and decisions on submitted measures, impractical timelines, a lack of rationale for rejected measures, and a lack of responsiveness to correct errors in measures.  The Coalition requested that CMS develop a standardized process for review of QCDR measures with structured timeframes for an initial review period, an appeals process, and a final review, and create an official database to store decisions on measures.

Click here to read the full letter.


PCRC Handout on QCDR Access to Medicare Claims Data

The Physician Registry Coalition prepared a handout on Qualified Clinical Data Registry (QCDR) access to Medicare claims data.  Neither the ResDAC process nor quasi-qualified entity program provides QCDRs with the type of access to Medicare claims data that satisfies the requirements to provide such data to QCDRs under Section 105 (b) of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).   Access to Medicare claims data is crucial to measuring quality improvement for QCDRs.  Therefore, the Coalition requests additional rulemaking separate from the ResDAC process and quasi-qualified entity status to provide QCDR the necessary access to Medicare claims data.

A PDF version of the handout can be viewed here.


CMS Releases Display Version of CY 2018 Quality Payment Program Proposed Rule

On June 20, 2017, the Centers For Medicare and Medicaid Services (CMS) released the display version of the CY 2018 Quality Payment program proposed rule, which will be published in the Federal Register on June 30, 2017.  The Quality Payment Program, which is updated annually as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), incentivizes physicians to increase the quality through participation in either Advanced Alternative Payment Models (APMs) or the Merit-based Incentive Payment System (MIPS).

CMS Administrator Seema Verma stated “We’ve heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient.  That’s why we’re taking a hard look at reducing burdens. By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork. CMS will continue to listen and take actionable steps towards alleviating burdens and improving health outcomes for all Americans that we serve.”  Comments on the proposed rule are due August 21, 2017.