Dear Secretary Azar:
We appreciate your continued efforts in working with Congress to achieve our shared goal that the
Quality Payment Program (QPP) enhance the physician experience while improving patient care
across the entire health care delivery system. Though much has been done to ease reporting
requirements for physicians who participate in Medicare’s quality improvement programs, there
is still more to do to facilitate providers’ efforts to address the needs of a growing and diversifying
patient population.
We believe Qualified Clinical Data Registries (QCDRs) have great potential to capture these
efforts, and translate them into data-driven policy changes to improve outcomes. To that end, we
would like to work with you to strengthen QCDRs by removing barriers that limit the utility and
usability of QCDRs for physicians participating in the QPP.
We appreciate the progress made with respect to this goal in the 2017 Merit-based Incentive
Payment System (MIPS) performance score adjustment that granted credit for participation in a
QCDR. Rewarding physicians for participating in QCDRs supports Congress’ goal of simplifying
reporting requirements, managing costs, and improving quality of care for all Americans. QCDR
participation is not only a way of measuring quality but also a means for improving clinical care.
However, improvements in the flow of secure patient information between QCDRs and providers’
electronic health records (EHR) is critical to the success and growth of the program. It has come
to our attention that barriers exist within some EHR systems that inhibit the transfer of patient
information to the QCDR. For example, some EHR vendors require providers to pay a large fee to
share their data with the registry. Additionally, some EHR vendors require the purchase of
intermediary software systems owned by the EHR in order to send information to the registry. We
are concerned that these practices may limit access to and discourage utilization of QCDRs; data
interoperability and data sharing must be a priority if QCDRs are to advance under QPP.
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