Re: QCDR Quality Measures
Dear Dr. Yong:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition)
are writing to express our concerns about recent email communications from the Centers for
Medicare & Medicaid Services (CMS) Physician Qualify Measures Management (PQMM) Team
to entities that operate Qualified Clinical Data Registries (QCDRs) under the existing Physician
Quality Reporting System (PQRS), which is soon to be transitioned into the Merit-based
Incentive Payment System (MIPS) pursuant to the Medicare Access and CHIP Reauthorization
Act of 2015 (MACRA). The emails “request” that the QCDRs consolidate one or more of their
proposed non-PQRS quality measures with (a) existing, traditional PQRS quality measures,
(b) other non-PQRS measures proposed by other QCDRs, or (c) non-PQRS measures proposed
by the QCDR to which the email is addressed. The emails state that the purpose of the request is
to streamline the entire set of non-PQRS QCDR measures to reduce redundancy and thereby
ensure the QCDR measures are “rigorous and defensible” and “will allow for performance
measurement across a broader cross-section of Eligible Clinicians allowing for a more robust
comparison of clinician performance.” While the emails are crafted as requests, they appear to
imply that if the QCDR does not comply, CMS will pick the QCDR measures that may be used
by clinicians in given specialties and eliminate the ones CMS finds to be redundant or otherwise
deficient.
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Read full letter here
