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.

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