Is MNCM a Clinical Data Registry?
After full review of the Quality Payment Program rules for the 2018 Performance Period, and consultation with Subject Matter Experts (SME) within CMS, MNCM has determined that providers submitting data to MNCM for any measure via the Direct Data Submission (DDS) method may meet requirements for reporting to a Clinical Data Registry (CDR), provided that the submitted data originated from CEHRT.
The SMEs with CMS differentiated the definition of a CDR from a Public Health Registry or Specialized Registry by stating, "Clinical Data Registries (CDRs) are administered by, or on behalf of, other non-public health agency entities. They provide information that can inform patients and their health care providers on the best course of treatment and for care improvements, and can support specialty reporting by developing reporting for areas not usually covered by public health agencies but that are important to a specialist's provision of care. CDRs can also be used to monitor health care quality and resource use."