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:

1. 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;
2. 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;
3. 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;
4. 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;
5. Create two separate benchmarks for reporting QCDR measures electronically and manually;
6. 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.