On November 20, 2017, the Physician Clinical Registry Coalition submitted a letter to the Centers for Medicare and Medicaid Services (CMS) outlining its concerns regarding the commercial misuse and licensing of MIPS measures.  The letter discusses the several instances of commercial entity misuses of MIPS measures, such as using measures for profit and not for the purposes of quality improvement, incorrect implementation of measures with clear guidelines, and greater risk for inaccuracies due to lack of operational experience with measure science.

We also asked CMS to extend the requirement that entities that use QCDR or MIPS measures developed by QCDRs must enter into a licensing agreement with the measure owner.  The Coalition believes there is no meaningful distinction between the MIPS and QCDR measures and therefore requests CMS to clarify that MIPS measure developers/owners, including medical societies and clinical data registries, can enforce copyrights, and that third parties wishing to use such measures must enter into licensing agreements with measure owners before they can properly use MIPS measures.

Click here to read the full letter.