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What it takes to be a 2027 QCDR or Qualified Registry: participants, MVPs and subgroup reporting
Summary
CMS presenters listed core approval requirements for 2027: compliance with the 2027 Medicare physician fee schedule final rule, supporting MIPS Value Pathways, subgroup reporting, and a minimum of 25 participants by Jan. 1 preceding the performance period.
John Jenkins, speaking for CMS, summarized the programmatic requirements for QCDRs and qualified registries, citing the 2027 Medicare physician fee schedule final rule and the QCDR/Qualified Registry fact sheet. "As CMS approved QCDRs and Qualified Registries, you're required to comply with all requirements set forth in the 2027 Medicare physician fee schedule final rule," he said.
Jenkins emphasized specific operational requirements: registries must support MVPs or secure an exception, enable subgroup reporting, and have at least 25 participants by Jan. 1 of the year prior to the performance period (for 2027 consideration that is Jan. 1, 2026). He warned that CMS has found applicants who did not maintain the required participant counts during review and urged careful documentation of participant lists.
