Dear Ms. Verma:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) appreciate
the opportunity to comment on the Centers for Medicare and Medicaid Services’ (CMS’s).
proposed rule to improve interoperability and access to health care data (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. The Coalition’s comments on the Proposed Rule focus largely on CMS’s
future rulemaking on interoperability activities as potential alternatives to measures in the
Promoting Interoperability Program, as well as CMS’s request for information (RFI) on
advancing interoperability across the care continuum
While the Coalition understands that this Proposed Rule focuses largely on patient access to
health care data, the Coalition hopes to work with CMS to expand provider access to data in
order to promote quality of care and enhance health care decision making. Provider access to data is essential to their ability to report complete and accurate information to clinical data
registries and thus for registries to fulfill their mission of improving quality of care through the
collection, analysis, and benchmarking of data on health care diagnoses, treatments, and
outcomes. The Coalition understands that this Proposed Rule is only the first phase of CMS’s
policymaking on interoperability and access to health care data. The Coalition looks forward to
working with CMS on these issues in future rulemaking
Read full letter here
