Once you've selected how you will report, the
Last week, we discussed the first step to reporting PQRS in 2016, selecting a submission mechanism. To briefly recap, there are three submission mechanisms that are viable for practices starting to report at this point in the year: Registry, EHR, and QCDR. Of these three options, Registry reporting has the highest rate of success and ease of submission.
✔ Only have to report on 20 unique patients
✔ One Measures Group counts as successful reporting
× Cannot use a measures group when reporting using the Group Practice Reporting Option (GPRO)
With few circumstantial exceptions, we recommend first assessing whether or not you can report a measures group. When possible, measures group reporting is the quickest way for an individual provider to report PQRS.
Measures groups are sets of PQRS Measures related by diagnosis or patient population. In 2016, there are 25 measures groups that can be used only when reporting via registry. To successfully report a measures groups, you must report 20 unique patients that meet the diagnostic criteria of the measures group (at least 11 of which are Medicare part B beneficiaries), meeting the quality action for each measure at least once.
Measures groups are only available if reporting through a Qualified PQRS Registry, like PQRSPRO. Additionally, measures groups cannot be used if you've opted to use the Group Practice Reporting Option (GPRO).
✔ Select 9 individual measures that cover 3 NQS domains
✔ Reporting 50% of eligible instances for each measure is considered successful reporting
✔ 1+ of the 9 measures must be a cross-cutting measure
If there are no measures groups that work for your practice, if you are reporting as a GPRO, or if you have a very small Medicare patient population, you should report using individual measures.
Unlike measures groups, individual measures can be reported through any submission mechanism. The number of available measures will vary by submission mechanism, and also by vendor used. Using an all-specialty registry like PQRSPRO will allow you access to the greatest number of individual measures.
| Reporting Mechanism | Individual Measures Available |
| Qualified PQRS Registry (PQRSPRO) | 198 |
| Electronic Health Record (EHR) Reporting | 63 |
| Qualified Clinical Data Registry | varies significantly |
| Claims Based Reporting | 79 |
To successfully report using individual measures, you must:
We find that cross-cutting measures are usually a point of confusion for providers new to reporting PQRS. A cross-cutting measure is simply an individual measure designed to capture a broad cross-section of your patient population. For the 2016 reporting period, there are 19 cross-cutting measures that can be used. The only situation in which a eligible group or provider would not include at least one cross cutting measure in their group of nine individual measures is if there were no face-to-face encounter codes billed during that calendar year.
If an eligible provider or group does not have enough applicable measures, or the applicable measures they do have do not cover 3 NQS domains, then they report the measures that they can, and their submission is subject to something called the Measures Applicability Validation (MAV) process.
✔ Report as many individual measures as possible, including one MAV cluster and a cross-cutting measure
✔ Should only be used if you cannot report using a measure group or sufficient individual measures.
This process confirms that eligible providers and groups that reported less than nine individual measures and or less than three NQS domains really couldn't report more measures.
CMS has defined clinically relevant clusters of measures, called MAV clusters. In order to successfully report using the MAV process, besides not being able to utilize measures groups or report to the individual measure reporting standard, a provider must report one clinically relevant cluster, all individual measures that apply to them, and one cross-cutting measure.
This process can be convoluted and confusing to understand, so if it looks like you will have to report PQRS using the MAV process, we recommend viewing our “Be a MAV Maverick” webinar recording, or talking to your submission mechanism vendor for assistance.
Next week, we will be delving further into what the requirement "50% of eligible instances" really means when reporting individual measures. Subscribe to weekly updates to receive an alert when this article is released! Additionally, if you prefer to learn by watching and interacting with people, we recommend registering for our "Getting Started with 2016 PQRS" webinar.