Re: [CMS-5061-F] – Medicare Program: Expanding Uses of Medicare Data by Qualified Entities
Dear Mr. Slavitt:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) are
writing to express our concerns about the “quasi-qualified entity” provisions of the recently issued final rule, “Medicare Program: Expanding Uses of Medicare Data by Qualified Entities” (the Final Rule).
The Coalition is a group of more than 20 medical societies and other
physician-led organizations that sponsor clinical data registries that collect identifiable patient
information for quality improvement and patient safety purposes to help participating providers
monitor clinical outcomes among their patients. We are committed to advocating for policies
that enable the development of clinical data registries and enhance their ability to improve
quality of care through the analysis and reporting of these outcomes. Over half the members of
the Coalition have been approved as qualified clinical data registries (QCDRs) and most of the
others are working toward that goal.
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