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 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.
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 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.