RE: Registries and the Quality Payment Program
Dear Chairman Crosson,
On behalf of the undersigned organizations, we are writing to highlight the significant benefits of clinical
data registries and the role they should play in achieving the goals of the Quality Payment Program
(QPP). While MedPAC is considering a recommendation to eliminate the Merit-Based Incentive Payment
System (MIPS), Congress recognized that it was essential to preserve a fee for service option under the
Medicare Access and CHIP Reauthorization Act (MACRA), primarily because many specialties do not
have a path to alternative payment models (APMS). In addition, MedPAC’s June 2017 report pointed out
that fee-for-service is the best low-cost option over APMs in some markets. We agree that improvements
should be made to MIPS to ensure the overall goals of the QPP are achieved. Congress has also
highlighted the benefits of clinical data registries in recent legislation. Registries have evolved
substantially and are being utilized to improve care delivery and patient outcomes.
Rather than repealing MIPS, rewarding clinicians and increasing MIPS incentives to participate in a
clinician-led qualified clinical data registry (QCDR) would significantly increase the performance and
value of MIPS. Specifically, we recommend full credit for the Advancing Care Information category of
MIPS to clinicians utilizing a certified electronic health record system to participate in a clinician-led
QCDR. In addition, based on the overall positive impact registries have on patient care and the healthcare
system, we would suggest, similar to the credit provided for participation in Patient-Centered Medical
Homes under Advanced APMs (A-APMs), the consideration of an additional pathway to APMs and an
exemption from MIPS for participants in clinical data registries.
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