PQRS FAQS

by 
August 27th, 2014

PQRS participation is important for healthcare providers. Several types of payment adjustments may be applied depending on how well providers meet PQRS criteria. To avoid negative payment adjustments or even gain positive payment adjustments (Value Based Modifier) by CMS, healthcare providers need to successfully participate in the CMS Physician Quality Reporting System (PQRS).

For detailed information about this program, please refer to Section C of the ChiroCode Deskbook.

Q

How do I report for the 2014 Physician Quality Reporting System (PQRS) if there are fewer than 9 applicable electronic clinical quality measures (eCQMs) across 3 National Quality Strategy (NQS) domains for my practice and does the 0% performance rate apply to 2014 PQRS EHR Reporting?

A

For 2014 PQRS eCQMs, the expectation is that eligible professionals (EPs) or group practices reporting via the Group Practice Reporting Option (GPRO) select 9 measures and 3 domains applicable to their practice, or report on as many measures and domains as they have available (up to 9 measures/3 domains) within their CEHRT EHR and with applicable Medicare patient data. If more than 9 measures are applicable, then EPs/group practices can select the 9 most appropriate for their practice (or can report on as many applicable measures over 9 as desired).

EPs/group practices can earn a 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment by meeting the following criteria for satisfactory reporting:

1. Using a direct EHR product that is Certified EHR Technology (CEHRT) or EHR data submission vendor that is CEHRT, report on at least 9 measures covering 3 National Quality Strategy (NQS) domains.

  • If the EP’s CEHRT does not contain patient data for at least 9 measures covering at least 3 domains, then the EP must report the measures for which there is Medicare patient data. An EP must report on at least 1 measure for which there is Medicare patient data to earn the 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment.

The 0% performance rate rule, where no patients in the denominator are in compliance and/or receive the correct quality action rule, does not apply to 2014 PQRS eCQMs. However, EPs should be aware that the VBM program, performance on eCQMs will be included when calculating the VBM. An EP must report on at least 1 measure with Medicare patient data meeting the denominator criteria, but the one patient does not need to meet numerator criteria.

 

Note: This rule is not applicable to groups reporting via GPRO web interface. Those groups must report all 22 GPRO WI measures both to earn a 2014 incentive and to avoid the 2016 payment adjustment.

If an EP/group practice has no applicable eCQMs with Medicare data, (s)he should choose a different reporting option for 2014 PQRS.

Source:  https://questions.cms.gov/faq.php?faqId=10046&id=5005

Q

What is the MAV?

A

FMAV is a validation process that will determine whether individual eligible professionals (EPs) or group practices should have reported additional measures OR additional domains. MAV determines 2014 Physician Quality Reporting System (PQRS) incentive eligibility and 2016 PQRS payment adjustment status for individual EPs and group practices. In the instance an individual EP or group practice has satisfactorily reported nine or more measures across three or more domains, MAV would not apply and the individual EP or group practice could earn the 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment.

MAV is applied to individual EPs and group practices that report less than nine measures OR less than three domains for PQRS. If MAV analytically determines that the EP or group practice could have reported additional measures or domains within the clinical cluster, then the 2014 PQRS incentive would not be earned and the 2016 PQRS payment adjustment may apply. Claims-based MAV is applicable to individual EPs, whereas registry-based MAV is applicable to individual EPs and group practices.

Source:  https://questions.cms.gov/faq.php?faqId=10058&id=5005  

Q

When does the MAV apply?

A

MAV applies if less than nine measures OR less than three domains are reported for claims-based and registry-based reporters. MAV does not apply to Measures Groups, Electronic Health Record (EHR), Group Practice Reporting Option (GPRO) Web Interface (WI), Certified Survey Vendor - Clinician & Group Surveys Consumer Assessment of Healthcare Providers and Systems (CG-CAHPS; CAHPS for PQRS), or Qualified Clinical Data Registry (QCDR) Reporting Mechanisms.

If reporting as an individual eligible professional (EP) via Claims, please utilize the claims-based MAV documents located at:  http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2014_PQRS_Claims_MeasureApplicabilityValidation_12132013.zip

If submitting as an individual EP or group practice via Registry, please utilize the registry-based MAV documents located at:  http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/PQRS/Downloads/2014_PQRS_Registry_MeasureApplicabilityValidation_12132013.zip

Source:  https://questions.cms.gov/faq.php?id=5005&faqId=10060   

Q

What happens if we report less than 9 measures across 3 domains?

A

Measure Applicability Validation (MAV) is automatically triggered in scenarios where less than nine measures OR less than three domains are satisfactorily reported by claims-based and registry-based reporters. If MAV analytically determines that the individual eligible professional (EP) or group practice could have reported additional measures or domains within the clinical cluster, then the 2014 Physician Quality Reporting System (PQRS) incentive would not be earned and the 2016 PQRS payment adjustment may apply.

If MAV analytically determines that the individual EP or group practice could NOT have reported additional measures or domains within the clinical cluster, the EP or group practice would be eligible for the 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment.

Source:  https://questions.cms.gov/faq.php?id=5005&faqId=10062   

Q

How does CMS apply the MAV Clinical Relation/Domain test for PQRS?

A

The MAV Clinical Relation/Domain Test is based on:

  1. If an individual eligible professional (EP) or group practice reports data for a measure, then that measure applies to their practice, and
  2. The concept that if one measure in a cluster of measures related to a particular clinical topic, OR individual EP, or group practice service is applicable to an individual EP’s or group’s practice, then other closely-related measures (measures in that same cluster) would also be applicable.

 

MAV will occur for claims-based reporting by individual EPs OR registry-based reporting by individual EPs and group practices who satisfactorily report quality data for less than nine measures OR less than three domains. If MAV analytically determines that the individual EP or group practice could have reported additional measures or domains within the clinical cluster, then the 2014 Physician Quality Reporting System (PQRS) incentive would not be earned and the 2016 PQRS payment adjustment may apply.

If MAV analytically determines that the individual EP or group practice could NOT have reported additional measures or domains within the clinical cluster, the individual EP or group practice would be eligible for the 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment.

Source:  https://questions.cms.gov/faq.php?id=5005&faqId=10064   

PQRS FAQS. (2014, August 27). Find-A-Code Articles. Retrieved from https://www.findacode.com/articles/pqrs-faqs-resource-321-25383.html

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