For Medicare providers participating in the Physician Quality Reporting System (PQRS) via claims or registry, measure applicability validation (MAV) is the process the Centers for Medicare and Medicaid Services (CMS) uses to determine if providers can still avoid the payment adjustment penalties even if they reported fewer than the required measures or domains.
Generally, to avoid the 2.0 percent payment adjustment in 2017, eligible providers who participate in PQRS via claims or registry for the 2015 reporting year must report 9 measures across 3 National Quality Strategy Domains (NQSD) for at least 50 percent of the denominator-eligible encounters. In addition, providers who have at least one face-to-face encounter with a Medicare patient must report at least 1 cross-cutting measure of the 9 measures reported.
However, for some specialities like anesthesiology, the PQRS program does not offer at least 9 measures covering 3 NQSDs. As well, anesthesiologists who report only ASA codes on their Medicare claims would not be considered to have had a face-to-face encounter. In situations like these where the conditions for successful reporting are not met, CMS will use MAV to determine if providers can still avoid the payment adjustment.
The MAV process is basically two steps and requires providers to successfully report 1 cross-cutting measure along with 1-8 total measures or 9 or more measures in only 1 or 2 NQSD.
Step one of MAV determines if measures that were successfully submitted fall within a clinically-related cluster. If so, if the cluster contains measures that weren’t submitted or measures in domains that weren’t submitted, CMS will consider those as possible measures that should have been reported.
For registry reporting, that means the provider should have reported those measures and will receive the 2.0% payment adjustment.
For claims reporting, step two of MAV establishes whether there were 15 or more eligible encounters identified in the denominator for the possible measures. If yes, then the provider should have reported those measures and will receive the 2.0 percent payment adjustment.
If there were no additional measures or domains that could have been reported or if additional measures had fewer than 15 denominator-eligible encounters, then the provider will be considered a successful PQRS reporter and will be spared the 2.0 percent payment adjustment.
An anesthesia cluster is available for both claims and registry reporting and includes the following 2 measures: Measure 76 Prevention of Central Venous Catheter (CVC) – Related Bloodstream Infections and Measure 193 Perioperative Temperature Management. Both are in the Patient Safety NQSD. According to CMS instructions, reporting Measure 76 alone does not require anesthesiologists to report Measure 193, but reporting Measure 193 alone would obligate providers to report Measure 76 if the minimum threshold of denominator-eligible encounters is met.
In addition, if 1 cross-cutting measure is not successfully reported, then MAV will be applied to determine if the provider had at least one face-to-face encounter and at least 15 or more eligible instances in the denominator of any cross-cutting measures. If so, the provider should have reported a cross-cutting measure and will be subject to the 2.0% payment adjustment.
Keep in mind that though ASA procedure codes are not considered face-to-face encounters, other services provided by anesthesiologists, including initial inpatient visit codes (99221-99223), subsequent hospital visit codes (99231-99233), the critical care code (99291), and outpatient visit codes (99201-99204, 99211-99214), are included on the face-to-face encounter list and in the denominator of some cross-cutting measures. Anesthesiologists who bill for these services should plan to report at least one cross-cutting measure.
The following resources will provide additional information about MAV, cross-cutting measures, and the PQRS program in general:
- CMS 2015 PQRS Implementation Guide;
- Face-to-Face Encounter List;
- Cross-Cutting Measures List;
- 2015 PQRS Individual Claims Registry Measure Specification Supporting Documents;
- 2015 PQRS Measure-Applicability Validation (MAV) Process for Claims-Based Reporting of Individual Measures;
- 2015 PQRS Measure-Applicability Validation (MAV) Process for Registry-Based Reporting of Individual Measures; and
- ASA 2015 PQRS FAQS.
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