This whitepaper offers valuable insights on how to choose the right reporting mechanism which can foster improvement in the quality of care.

1. April 2019
QCDR or QR?
Selecting the Correct
Reporting Mechanism
White Paper

2. Qualified Clinical Data Registry (QCDR) is a CMS
approved entity that collects and submits Merit-based
Incentive Payment System (MIPS) and non-MIPS
measures based clinical data for CMS review and
approval.
Clinicians work directly with their chosen registry to
submit data on the selected measures or specialty set
of measures. QCDR can support custom quality
measures, but are reviewed and approved annually by
CMS.
Quality Registries (QR) are different than QCDR since
they are limited to submitting measures within the
QPP program defined by CMS.
A Qualified Registry is approved to collect and submit
clinical data from MIPS eligible clinicians, groups or
individuals to CMS.
This includes measures and / or activity data for the
following MIPS categories - Quality, Promoting
Interoperability, Improvement and Activities, and Cost.
WHAT IS QCDR AND QR?
1
ADVANTAGE OF QCDR / QR
▪ Submissions for all payer data
▪ Probability of higher financial
incentives
▪ Reduced burden of regulatory
submissions
▪ Real-time insights of performance
▪ More number of measures available
▪ Specialty specific measure à la carte
selection
▪ Leverage GPRO advantage
▪ Digitally equipped to connect and
acquire data
▪ Access to charts

3. A QCDR or QR needs to equip itself with a state-of-art,
extensible technology to support data ingestion,
processing, analytics and submissions. It needs:
▪ A robust data ingestion and reconciliation engine
that maintains a single source of truth (SSOT) for
physicians and healthcare delivery organizations,
and has the capability to extend the engine as
required
▪ To support Physician offices at the point-of-care
with tools that capture MIPS specific codes and
invoice them
▪ Furthermore, a measure processing rules engine to
calculate Physician (and Physician groups)
performance, and compare it with CMS published
benchmarks is required
▪ An application where the registry can view the
performance of their Physicians (and Physician
groups), manage their attributes, and perform
submissions to CMS on their behalf
▪ A portal for Physicians to perform MIPS mandatory
requirements and view performance on near real-
time basis. This will allow them to take necessary
measures to positively impact their scores
▪ It is critical for registries to be audit ready, store
and view historic data to support submissions
▪ Real-time reports and analytics aid in effective
outreach and support client communications. Here,
a sandbox helps to slice and dice data which
enables to view financial, regulatory and
operational statuses
▪ Advanced registries continue to collaborate with
CMS to pioneer processes and policies with their
retrospective and predictive analytics. QCDRs / QRs
are capable of collaborating with research
organizations by data de-identification
TECHNICAL CHALLENGES
2
Data integrity, real-time insight to data, &
being extensible is the foundation for any
registry to be successful.

4. There are multiple ways to report data to CMS, and the choice to report and methods available depend on a)
Whether you belong to a group b) Size of practice c) Type of information technology used and d) Performance
category
REPORTING MECHANISMS
3
Method How it works
Individual
Submission
Group
Submission
Virtual
Group
Claims CMS processes data via Medicare claims through
routine billing process
Yes No No
Electronic
Health
Record
Clinicians submit data to CMS directly through their
EHR system or a qualified health IT vendor submits
the data on their behalf
Yes Yes Yes
CMS Web
Interface
A secure internet-based application available to pre-
registered groups of 25 or more eligible Clinicians.
CMS partially pre-populates the CMS Web interface
with claims data
No Yes Yes
QCDR CMS approved entity to submit MIPS, non-MIPS and
custom measures
Yes Yes Yes
Quality
Registry
CMS approved registry which collects clinical data
and submits it to CMS on their behalf
Yes Yes Yes

5. With CMS MIPS program structure evolving every year
and increasing penalties and incentives, many
organizations tend to transfer the burden of
submissions to either a QCDR or QR.
Along with QCDRs and QRs, claims-based submission,
EHR submission, the Web Interface option, and the
new CMS attestation portal for reporting Quality,
Promoting Interoperability and Improvement Activities
are causing confusion among providers in choosing
the correct option to suit their needs.
The following suggestions can help Providers select a
suitable reporting option:
▪ Look at the size of the practice. Smaller practices
generally prefer claims submissions, since the
registry isn’t a regulatory option for them.
Additionally, CMS considers the claims submitted
for MIPS submission, avoiding any additional
processes for CMS submission. But the scores
would be available retrospectively
▪ Post claims-based submissions, the data cannot be
modified (even for legitimate scenarios). Registries
are equipped with resources to change data or
amend additional data, interact with providers to
understand their problem and modify the data
under legal scenarios.
▪ But, Registry submission is suitable when registries
offer submission for same specialties served by
providers
▪ Claim submissions to CMS can take place only for
Medicare beneficiaries. However, a qualified
registry can submit data across all payers,
increasing the probability of higher performance
▪ QCDRs and QRs seldom provide a dashboard to
view near real-time performance, which allow to
track and improve performance, instead of using
claim based reporting options which provide
results post-submission
▪ Same data used for claims-based reporting can be
used by a registry, and providers can view where
they stand based on measured performance
IS QR / QCDR REPORTING RIGHT FOR YOU? (1/2)
4

6. ▪ Providers with few primary care physicians tend to
opt for existing EHRs. Some EHRs support data
capture for specific configurable measure sets.
▪ However, data can be pulled from certain EHR
fields and is subject the EHR’s ability (year-on-year)
to accommodate more data
▪ Registries, on the other hand, focus on submissions
and are technologically equipped to handle data
from multiple sources to ensure successful
submission
▪ Provider claims data can be integrated with the
system used by QCDRs. An established registry
with set processes enables provider data to flow
seamlessly in the registry
▪ For CMS audits, registries can support the audit
workflow by maintaining and proving the records
▪ Provider communications department of a
qualified registry can help providers update and
explain any changes in the MIPS program
▪ QCDRs and QRs offer an option for group
submission as well as individual submissions,
extrapolating an advantage of submitting under a
group with common Tax Identification Number
▪ For performance improvement, providers should
turn to a Registry or QCDR for more advanced
analytics and flexibility
▪ In 2018, Registry reporting provides access to 249
measures across specialties, compared to
previously available 53 EHR measures, 74 claims-
based measures, and 15 web interface measures
5
IS QR / QCDR REPORTING RIGHT FOR YOU? (2/2)

7. As a Physician or Physician group, list of CMS-
approved Qualified Clinician Data Registries and
Qualified Registries are published each year by CMS.
Check if the QR or QCDR supports all Physicians and
Clinician types and their related specialties. Also look
for specialties specific Quality, PI, IA activities
supported by a QR.
CMS recognizes that adequate time is needed to plan
for MIPS reporting, and is making efforts to approve
QCDRs and QRs before the beginning of the calendar
year.
Contact your preferred QCDR to obtain their measure
specifications and get started. As a QCDR, select a
technology vendor (or an in-house technology group)
that can support the technological demands of a
registry.
Things to keep in mind before choosing a technology
vendor –
1. Ensure the analytics platform is ONC and NCQA
certified
2. A DIY rules (regulatory, contractual, operational,
etc.) management application will empower
business users to edit, build and manage rules
without IT
3. For data management and integration needs, a
modular, scalable and configurable platform will
help increase the speed of deployment at a cost
4. Ensure the technology vendor has the
organization’s compliance and audit needs in mind
Eventually, CMS provides financial benefits based on
the best score irrespective of the type of submission
selected.
6
CONCLUSION

8. 7
▪ https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-
Programs/MACRA-MIPS-and-APMs/2018-QCDR_Registry_JIRA_Demo_2017-08-25_slides.pdf
▪ https://qpp.cms.gov/about/resource-library
▪ https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-
Instruments/MMS/Downloads/A-Brief-Overview-of-Qualified-Clinical-Data-Registries.pdf
▪ https://qpp-cm-prod-
content.s3.amazonaws.com/uploads/156/2018%20QCDR%20Qualified%20Posting_FINALv14.xlsx
▪ https://www.aha.org/system/files/content/17/pac-mips-qcdr-list.pdf
▪ https://qpp.cms.gov/mips/quality-measures
▪ https://www.cms.gov/Outreach-and-Education/Outreach/NPC/Downloads/2018-05-16-QPP-
Presentation.pdf
▪ https://qpp-cm-prod-
content.s3.amazonaws.com/uploads/350/2019%20MIPS%20Quality%20Performance%20Category
%20Factsheet.pdf
▪ https://qpp.cms.gov/mips/individual-or-group-participation
REFERENCES

9. 8
ABOUT THE AUTHOR
Sheetal Sawardekar
Senior Healthcare Consultant, CitiusTech
sheetal.sawardekar@citiustech.com
Sheetal is a CPHIMS certified Senior Healthcare Consultant with 14+ years of experience in the Medical Device
and Healthcare IT industry.
She plays the role of Consultant and Business Analyst for the Provider market, and has in-depth knowledge
about medical device development (monitoring, diagnostic and therapeutic devices). She holds a Masters
degree in Biomedical Engineering.

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