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Ms. Molly MacHarris
Quality Measurement and Value-Based Incentives Group
Center for Clinical Standards and Quality
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244-8013
Room S3-02-01
Dear Ms. MacHarris:
The Physician Clinical Registry Coalition (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. Most of the members of the Coalition
have been approved as Qualified Clinical Data Registries (QCDRs) or are working
towards achieving such status.
The undersigned Coalition members agree with the Centers for Medicare & Medicaid
Services’ (CMS’) goal of reducing burdens in the Merit-Based Incentive Payment System
(MIPS), but we are concerned with the potential negative impact of MIPS Value Pathway
(MVP) on clinician-led QCDRs. Specifically, we strongly recommend that CMS delay
the introduction of MVPs, promote specialty-specific sub-group reporting in large
groups, and ensure that meaningful participation in QCDRs is neither discouraged nor
impeded by the developments of MVPs.
Read full letter here
