RE: Data Validation for Merit-based Incentive Payment System Performance Year 2020
Dear Dr. Green and Ms. Sugumar:
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 members of the Coalition respectfully request that the Centers for Medicare and
Medicaid Services (CMS) and its contractors honor the 2020 Merit-based Incentive Payment
System (MIPS) performance year data validation plans that the Qualified Registries (QRs) and
QCDRs submitted in September of 2019 as part of the annual self-nomination process and that
CMS approved late last year. We are concerned that CMS and its contractors require additional
validation and auditing criteria beyond those set forth in the final rule updating the Quality
Payment Program for 2020 (2020 Final Rule). We do not believe it is appropriate or legal for
CMS to arbitrarily and retroactively apply unpublished data validation and auditing criteria to the
2020 performance year.
Read full letter here
