Re: Concerns Regarding QCDR Measure Review and Self-Nomination Process
Dear Dr. Yong:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) are
writing to express our concerns about the difficulties we have experienced with the Qualified
Clinical Data Registry (QCDR) measure review and self-nomination process under the Meritbased Incentive Payment System (MIPS), which was established by the Medicare Access and
CHIP Reauthorization Act of 2015 (MACRA). While we appreciate the efforts that your office
has made to increase the flexibility and responsiveness of the QCDR program, there are several
areas that still require improvement.
We recognize that the CY 2018 Updates to the Quality Payment Program (QPP) proposed rule
(CY 2018 proposed rule) addresses some aspects of the data submission process by third-party
intermediaries. We plan to comment on the proposed rule through the official rulemaking
process, but believe the issues we describe in this letter warrant a separate letter and immediate
attention and discussion. We offer these comments as part of our continuing dialogue with your
office about these important matters.
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Read full letter here
