Re: CMS-5517-P – Medicare Program; Merit-Based Incentive Payment System (MIPS) and
Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for
Physician-Focused Payment Models
Dear Mr. Slavitt:
The undersigned members of the Physician Clinical Registry Coalition (the Coalition) appreciate
the opportunity to comment on the proposed rule on the implementation of the Medicare Access
and CHIP Reauthorization Act of 2015 (MACRA) (Pub. L. 114-10) provisions related to MIPS
and APMs (the Proposed Rule). The Coalition is a group of more than 20 medical societies and
other physician-led organizations that sponsor 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 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 other members are working towards achieving QCDR status.
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