The Centers for Medicare & Medicaid Services (CMS) requires all eligible professionals (EPs) to successfully report on at least nine measures covering at least three National Quality Strategy (NQS) domains during 2015 to avoid Physician Quality Reporting System (PQRS) penalties. CMS also recognizes that many clinicians may not have nine measures available to report, so they have devised the Measure Applicability Validation (MAV) program that will allow clinicians to avoid the PQRS penalties while reporting fewer than nine measures or fewer than three quality domains.

How Does the MAV Work?

If an eligible professional reports fewer than nine measures (or three domains), CMS will evaluate the EP’s claims to see if there were any other measures that the EP had at least 15 opportunities to report on during the year, yet they did not report the measure(s). CMS will only look for other reportable measures that belong to the same MAV clusters as the measures already being reported by that clinician. MAV clusters are defined differently depending on the method of reporting/PQRS data submission: claims-based or registry-based.

What Are Cross-Cutting Measures?

In addition to reporting at least nine measures across three NQS domains, if the clinician has at least one face-to-face patient encounter during the year, at least one of their reported measures must come from a short list of “cross-cutting” measures defined by CMS. Successfully reporting nine measures, across three domains, including one cross-cutting measure, satisfies the 2015 PQRS reporting requirements.

Potential Measures for Emergency Care

Emergency Medicine and the MAV Process

• Eligible providers can still satisfy PQRS and avoid the penalty by reporting on less than nine measures, but would be subject to the MAV process to determine whether they reported on as many measures as are applicable; this will also determine if they could have reported on any cross cutting measures.
• About 99 percent of emergency providers will not have any Medicare patients that fall into measures 91, 93, 254, and 255 above, so it is highly unlikely that those measures would be counted toward the nine-measure goal for most providers.
• Emergency physicians should also beware of reporting on any measures outside of their cluster (with the exception of 76 and 317), as reporting additional measures may trigger additional clusters as noted in the table above.
• On January 19, 2015, CMS released the 2015 MAV process: Claims-based MAV for emergency care = Cluster 4 + 1 Cross-Cutting Measure

Claims-based MAV for Emergency Care