PQRS Measure Applicability Validation

In 2015 psychologists and other eligible professionals (EPs) participating in Medicare’s Physician Quality Reporting System (PQRS) are expected to report on nine measures across three domains. Failure to successfully report could result in a 2 percent payment reduction in 2017. 

If an EP reports fewer measures or domains than required in 2015 (for example, reporting seven measures across three domains or nine measures across two domains), the Centers for Medicare and Medicaid Services (CMS) will apply a process known as Measure Applicability Validation (MAV) to determine if there were other related measures that may have been reported. The MAV process examines whether the measures reported are part of a clinically related “cluster,” meaning a group of measures applicable to a particular health problem.

The MAV process could potentially shield EPs who were unable to meet reporting requirements from the 2 percent penalty on all Medicare payments in 2017. 

Who is eligible for MAV?

MAV applies to individuals reporting via claims and to individuals or group practices using a registry who submit less than nine measures across three domains. 

Importantly, EPs who have face-to-face encounters with patients must include at least one “cross-cutting” measure in order to be eligible for MAV. Cross-cutting measures are selected PQRS measures that focus on patient status and were designed to be used by EPs in many different health care specialties. This requirement is critical: If EPs who have face-to-face encounters with patients fail to report a cross-cutting measure they will be automatically subject to the 2 percent penalty, regardless of how many measures they report. 

A list of all measures designated as cross-cutting is available online from CMS. The cross-cutting measures most likely to be used by psychologists are:

Cross-cutting measure	Domain	Available reporting methods
No. 47: Advance Care Plan	Communication and Care Coordination	Claims Registry Measure Group: Dementia
No. 128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan	Communication and Care Coordination	Claims Registry EHR
No. 130: Documentation of Current Medications in the Medical Record	Patient Safety	Claims Registry EHR
No. 131: Pain Assessment and Follow-Up	Community/ Population Health	Claims Registry
No. 134: Preventive Care and Screening: Screening for Clinical Depression and Follow-Up Plan	Community/ Population Health	Claims Registry EHR

How does MAV work? 

Claims-based reporting and registry reporting have separate but similar MAV processes. For both types of reporting CMS examines “clinical clusters” that include one or more of the measures that the EP did report. Most clusters reflect care for specific conditions (such as diabetes or osteoporosis). After identifying a clinical cluster, CMS determines whether additional cluster measures could have been reported by the EP based on the services provided and the patient’s diagnosis. CMS looks for 15 patient encounters where another measure could have applied.

There are no clusters that focus on mental illness or mental health care for 2015. Most of the measures likely to be used by psychologists are either not in any clusters or are not eligible for claims-based reporting and thus are not subject to the claims-based MAV review. For example, measure #181, Elder Maltreatment Screening and Follow-Up Plan, is not part of any cluster so reporting this measure will not trigger a review of any other specific measures. As a result, it is likely that the MAV process will not find additional measures on which the psychologist could have reported, and the psychologist will not be subject to the 2 percent penalty for 2017. 

Although registry reporting has twice as many clinical clusters as claims-based reporting, none of the clusters revolves around mental health. As with claims-based reporting, the measures most likely to be used by psychologists, including the Preventive Care and Screening measures for Body-Mass Index, Clinical Depression Screening, Unhealthy Alcohol Use, and High Blood Pressure, are not part of any clinical clusters used in the registry MAV process. 

EPs reporting through registries have the option of reporting on a measures group rather than individual measures. With a measures group the EP needs to report each measure in the group for 20 patients, of which 11 or more must be Medicare Part B fee-for-service patients. There is a measures group on dementia that involves many services provided by psychologists including neuropsychological testing.

For more information about PQRS and the MAV process, contact the Government Relations office by phone at (202) 336-5889 or via email.