On September 10, 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 on the CY 2019 Physician Fee Schedule proposed rule, which included proposed changes to the Quality Payment Program.

While the Coalition supports CMS’s proposal to revise the definition of a qualified clinical data registry (“QCDR”) to require clinical expertise in medicine and quality measure development, the Coalition expressed significant concerns about other proposals related to QCDRs and the use of QCDR measures in the Merit-based Incentive Payment System (“MIPS”) program. Among other concerns, the Coalition strongly urged CMS to reject a proposal that would require QCDR measure owners to enter into license agreements with CMS as a condition of measure approval. The Coalition strongly opposes this proposal because it undermines QCDR measure ownership and investment in measure development, as well as violates the intellectual property rights of QCDRs.

The Coalition also advised CMS to reconsider its proposals or seek additional input on the self-nomination process, treatment of topped out measures, development of QCDR benchmarks, the removal of the Public Health and Clinical Data Exchange objective from the Promoting Interoperability performance category, and the facility-based measurement scoring option.

Click here to read the full letter.