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 emergency medicine, the PQRS program does not offer at least 9 measures covering 3 NQSDs. In these situations 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 emergency care cluster is available for claims reporting and includes the following 3 measures: Measure 54 Emergency Medicine: 12-Lead Electrocardiogram (ECG) Performed for Non-Traumatic Chest Pain, Measure 254 Ultrasound Determination of Pregnancy Location for Pregnant Patients with Abdominal Pain, and Measure 255 Rh Immunoglobulin (Rhogam) for Rh-Negative Pregnant Women at Risk of Fetal Blood Exposure. All three are in the Effective Clinical Care NQSD. There is no emergency care cluster for qualified registry reporting. Since pregnancy is not a common diagnosis for the majority of Medicare patients and the number of denominator-eligible encounters likely would not pass the minimum threshold test for many providers, Measure 54 is really the primary claims measure for emergency physicians to report.
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 common emergency medicine E&M codes are on the list of face-to-face encounters and are in the denominator of two cross-cutting measures. As a result, EM
providers who do not successfully submit one cross-cutting measure will be subject to the 2.0% payment adjustment.
The two cross-cutting measures for both claims and registry reporting that include Emergency Medicine E&M codes in the denominator are Measure 1-Diabetes: Hemoglobin A1c Poor Control and Measure 317-Screening for High Blood Pressure and Follow-Up Documented.
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; and
- 2015 PQRS Measure-Applicability Validation (MAV) Process for Registry-Based Reporting of Individual Measures.
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