Re: CMS-1693-P – Medicare Program; Revisions to Payment Policies Under the Physician
Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings
Program Requirements; Quality Payment Program; and Medicaid Promoting
Interoperability Program
Dear Ms. Verma:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) appreciate
the opportunity to comment on the proposed rule on calendar year (CY) 2019 updates to the
Physician Fee Schedule, Medicare Shared Savings Program, Quality Payment Program (QPP),
and Medicaid Promoting Interoperability Program (the Proposed Rule). The Coalition is a
group of medical society-sponsored clinical data registries that collect and analyze clinical
outcomes data to identify best practices and improve patient care. We are committed to
advocating for policies that encourage and enable the development of clinical data registries and
enhance their ability to improve quality of care through the analysis and reporting of clinical
outcomes. Most of the members of the Coalition have been approved as qualified clinical data
registries (QCDRs) or are working towards achieving QCDR status.
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