Powers Principal Rob Portman and Associate Christina Krysinski recently represented the Physician Clinical Registry Coalition in a number of advocacy efforts related to interoperability and data sharing, as well as the participation of qualified clinical data registries (QCDRs) in the Merit-based Incentive Payment System (MIPS).  

The 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. The Coalition is committed to advocating for policies that encourage and enable the development of clinical data registries and enhance their ability to improve quality of care through the analysis and reporting of clinical outcomes.

On the interoperability and data sharing front, the Coalition submitted a comment letter to the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services in response to a request for information on modifying the HIPAA Rules to improve coordinated care.  Click here to read the full letter.  The Coalition also submitted comments on the Office of the National Coordinator for Health Information Technology’s (ONC) draft Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs and ONC’s request for information on the Electronic Health Record (EHR) Reporting Program established by the 21st Century Cures Act.  The Coalition’s comments on the draft EHR burden reduction strategy are available here and its response to the EHR Reporting Program request for information is available here.

In light of the ONC’s recently released proposed rule on information blocking, the Coalition looks forward to working with OCR, ONC, and other divisions of the U.S. Department of Health and Human Services to promote data sharing and interoperability and reduce regulatory and administrative burden.

As a part of its ongoing dialogue with the Centers for Medicare and Medicaid Services (CMS) about the QCDR program and QCDR participation in MIPS, the Coalition participated in a “white boarding” session with officials from CMS, the Council for Medical Specialty Societies (“CMSS”), and PCPI on February 6, 2019.  The session focused on improving the QCDR measure review process, licensing and harmonization of QCDR measures, and other issues impacting QCDR participation in MIPS.

The white boarding session came at a key time as CMS embarks on drafting the Quality Payment Program proposed rule for CY 2020.  The Coalition submitted a letter to CMS in December 2018 that identified many of the issues discussed in the white boarding session.  The full letter is available here.  The Coalition also advocated for solutions to many of these issues in its comments on the CY 2019 Physician Fee Schedule and Quality Payment Program proposed rule.  The Coalition’s comments are available here.

For more information on the Coalition, please contact Rob Portman at (202) 872-6756 or Rob.Portman@powerslaw.com or Christina Krysinski at (202) 872-6732 or Christina.Krysinski@powerslaw.com.