Qualified Clinical Data Registries Can Help with MIPS, MOCs and More

A note from the UHMS QUARC Committee co-chair

The Hyperbaric Oxygen Therapy Registry (HBOTR) provides much-needed national benchmarking and quality measurement services for hyperbaric medicine (https://clinicaltrials.gov/ct2/show/NCT02483650).

One of the more confusing areas of registries is the QCDR, or Qualified Clinical Data Registry. All medical specialty societies have them. There are about 40 medical specialties and subspecialties, and at this year’s meeting of the Council of Medical Specialty Societies (http://www.pehrc.org/member/council-medical-specialty-societies-cmss) – which I attended – those 40 specialties had a total of 49 registries. An interesting note: The average cost for setting up a registry is $10 million dollars.

All specialty societies use their QCDRs for these purposes:

  • Merit-Based Incentive Payment System (MIPS) participation for members (so members of the society can submit required data through the same entity)
  • The development of quality measures for their specialty or subspecialty (since not all specialties are represented in the quality measures arena). The UHMS sponsored the development of quality measures that were approved by CMS, some of which we have been able to keep despite low participation and some of which we have lost
  • As part of facility accreditation programs (e.g., bariatric centers, trauma centers, stroke centers, etc.)
  • Physician Maintenance of Certification (MOC) for physician specialty designation
  • Research – data are used to demonstrate the benefit of various therapies
  • Revenue generation for the organization (data is sold to manufacturers and pharmaceutical companies)
  • Congressional action – nearly all have annual “fly ins” to Congress to discuss the areas where additional research is needed because outcomes are not where they need to be (that’s how cardiologists and oncologists are so successful)
  • Preparation for future payment programs, for example, to understand the impact of bundled payment

Most big societies have several different registries, some of which target specific interests or interventions (e.g., drug-eluting stents). In some specialties, registry submission is mandatory for payment. Ironically, cardiology worries that the “good luck of mandatory reporting might not last forever.” Mandatory reporting (e.g., for implanted defibrillators) ensures universal participation, and thus data that can be sold at a profit to the organization. The National Cardiovascular Data Registry has received $48 million from various sources. 

Several societies have linked their data to the Medicare Claims dataset so they can evaluate the cost per beneficiary of various interventions. The radionecrosis study the UHMS is struggling to do with claims alone would be easier to do through a QCDR because it is possible to determine which individuals are the right patients and what their clinical outcome was – and then link THAT dataset to claims. It dramatically reduces the overall cost and increases the success rate of projects.

I set up a QCDR for the UHMS based on my traumatic experiences as UHMS President when we nearly lost HBOT physician and hospital payment overnight. It is unfortunate that something I set up for the good of the field has been perceived as commercial or biased. It’s a 501c non-profit (although it receives no contributions) and QCDRs are incredibly expensive to create and support. 

The UHMS successfully used the data from this QCDR in 2017 to defend the physician reimbursement rate for 99183 when the RUC (AMA specialty Review Update Committee) did its analysis. No similar data were available from other sources. 

QCDRs offer a pathway to survival for services that CMS threatens to curtail or stop paying for through the submission of “appropriate use” quality measures. 

Here’s a link to an article about how the hyperbaric oxygen QCDR could be a lifeboat: “Hyperbaric Medicine Quality Reporting: Building an Ark to Ensure Survival,” March 2018: https://www.todayswoundclinic.com/ articles/hyperbaric-medicine-quality-reporting-building-ark-ensure-survival 

This next article discusses how wound care practitioners can participate in a QCDR for MIPS credit, which enables them to optimize their MIPS score: www.liebertpub.com/doi/abs/10.1089/ wound.2018.0830?journalCode=wound 

If you are interested in knowing more about payment implications, I just finished a seven-part blog on the topic called “Counting the Cost, and a Roadmap to Survival.” 

The first installment is here, but all seven are available: https://carolinefifemd. com/2019/07/10/counting-the-cost-and-a-roadmap-to-survival-part-1-of-7/ 

For more information on the Hyperbaric Oxygen Therapy Registry see: https://www. uhms.org/publications/uhm-journal/uhm-journal-ahead-of-print-public.html 

Note: This article was taken from an email communication that was a follow-up to a UHMS Corporate Town Hall Meeting and printed in Pressure, the open-access newsletter of the UHMS. 

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