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.

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 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.