Re: CMS-1694-P – Medicare Programs: Hospital Inpatient Prospective Payment Systems
for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System
and Proposed Policy Changes and Fiscal Year 2019 Rates; Proposed Quality Reporting
Requirements for Specific Providers; Proposed Medicare and Medicaid Electronic Health
Record (EHR) Incentive Programs (Promoting Interoperability Programs) Requirements
for Eligible Hospitals, Critical Access Hospitals, and Eligible Professionals; Medicare Cost
Reporting Requirements; and Physician Certification and Recertification of Claims
Dear Ms. Verma:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) appreciate
the opportunity to comment on the proposed rule on changes to the Medicare Hospital Inpatient
Prospective Payment System (IPPS) for FY 2019, specifically the Medicare and Medicaid
Electronic Health Record (EHR) Incentive Programs (Promoting Interoperability Programs) (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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