Letter to Representatives

The Physician Clinical Registry Coalition (“PCRC”) recently provided comments to Congress regarding 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. PCRC expressed concerns regarding current CMS policies on measure testing, data validation, measure harmonization, topped out measures, cost measures, the MIPS Value Pathway framework, and the lack of meaningful access to Medicare claims data. PCRC requested legislative intervention to ensure that CMS is properly implementing the plain language and intent of MACRA. PCRC also expressed appreciation for the inclusion of language in the bipartisan legislation-H.R. 5394, the Meaningful Access to Federal Health Plan Claims Data Act-that would help address CMS’s failure to provide QCDR’s and clinician-led clinical data registries with meaningful access to federal claims data for research and quality improvement purposes.

Click here to read the letter to Representatives Bera, Bucshon, Schrier, Burgess, Blumenauer, Wenstrup, Schneider, and Miller-Meeks.

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.