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.
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.
The Centers For Medicare and Medicaid Services (CMS) posted the Measures Under Consideration (MUC) list for 2018 pre-rulemaking. Please see the announcement on the CMS blog here. Below is a short summary from Modern Healthcare:
Modern Healthcare reports that CMS released a list of 32 measures Thursday that are “under consideration for Medicare’s quality reporting and value-based purchasing programs.” Last year, CMS considered almost 100 measures. The smaller number of measures is “in line with CMS Administrator Seema Verma’s focus on reducing regulatory burden for providers” and the agency’s Meaningful Measures initiative. The list was culled from a pool of 184 submitted by stakeholders.
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.
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.
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:
- 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;
- 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;
- 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;
- 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;
- Create two separate benchmarks for reporting QCDR measures electronically and manually;
- 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.
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.
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.