How CMS applies the PQRS Measure-Applicability Validation (MAV) process

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Most PQRS participants have heard about the CMS Measure-Applicability Validation (MAV) process, but few can describe exactly how it works. You probably know that MAV is the process that could allow providers to report fewer than nine quality measures to CMS while still meeting program requirements, but it is critical for anyone considering this option to understand the details of how it is applied or you’ll risk getting hit with the penalty.

When does MAV apply?

In general, the MAV process is applied anytime a provider reports fewer than nine quality measures across three National Quality Strategy domains. However, there are some variations to that theme:

  • The MAV process is only applied to individual providers or group practices that report fewer than the nine required measures across three National Quality Strategy domains to CMS via the claims-based reporting option or the registry reporting.
  • Providers who see patients in face-to-face encounters and report fewer than nine quality measures to CMS are still subject to cross-cutting measure requirements. This means that before CMS determines whether you have met the requirements of the MAV, they will first determine whether you meet the face-to-face encounter requirement. CMS will then analyze claims data to determine if at least 15 cross-cutting measure denominator eligible encounters are associated with you, and if you did not report a cross-cutting measure, then the 2017 PQRS payment adjustment will be automatically applied. This means that providers who see patients in face-to-face encounters and report fewer than nine measures must ensure that at least one of the measures they do report to CMS is a cross-cutting measure.
  • CMS will still apply the MAV process if providers who report the required nine measures across three domains do not have at least one patient or procedure meeting performance in the numerator of the measures. For measures that move towards 100%, indicating a higher-quality outcome, this means the rate must be greater than 0%. For inverse measures where higher quality moves the rate toward 0%, the rate must be less than 100%.

It is important to note that while CMS has made information about the MAV process publicly available—and while we have done our best to explain it in this blog post—there is always the possibility of individually specific factors that may result in your MAV review being different from others. Always confer with a legal professional and know that relying on the MAV is taking a risk that may not meet reward. We encourage you to review the specific statutes, regulations, and other interpretive materials for a full and accurate statement of their contents.

If you have specific questions about how the MAV process applies in your case, you can Ask Able at this link or to the right of this post.


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