RE: Concerns Regarding Qualified Clinical Data Registries and MIPS
Dear Dr. Green and Ms. Sugumar:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) are
writing to express our concerns and offer our suggestions regarding several issues that we have
experienced as Qualified Clinical Data Registries (QCDRs) participating in the Merit-based
Incentive Payment System (MIPS). 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 QCDRs or are working towards achieving QCDR status. We
previously sent a letter to your office, dated July 11, 2017, in which we discussed concerns
regarding the QCDR measure review and self-nomination process and offered to work with the
Centers for Medicare and Medicaid Services (CMS) to develop a more organized, transparent,
and consistent process in the future. A copy of that letter is attached. We offer these comments
as part of our continuing dialogue with your office about the QCDR program and QCDR
participation in MIPS.
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Read full letter here
