2015 CMS Guidance (FAQ# 12168) on Cross-Cutting Measures and PQRS Reporting

Cross-cutting measures are any measures that are broadly applicable across multiple clinical settings and eligible professionals (EPs) or group practices within a variety of specialties. The requirement of reporting cross-cutting measures is new to the Physician Quality Reporting System PQRS) program beginning in 2015.

2015 Program Year Update: PQRS and Physician Value-based Modifier (VM)

The Centers for Medicare and Medicaid Services (CMS) Physician Quality Reporting System (PQRS) is a reporting program that currently uses both incentive payments (bonus) and payment adjustments (penalty) to encourage physicians to submit quality information to CMS. The incentives and adjustments are based on payments for covered Physician Fee Schedule services furnished to Medicare Part B Fee-for-Service beneficiaries.

Calendar year 2014 was the last year for a PQRS incentive. In 2015 and beyond, there is potential to obtain an incentive under the Physician Value Based Payment Modifier (VM) program.

Take advantage of the Medicare Learning Network (MLN) Web-Based Training courses related to PQRS. These self-paced modules will help your practice stay up-to-date on new reporting requirements and changes for the coming year. For more information on course descriptions and learning objectives see here.


2015 PQRS and Physician Value Based Payment Modifier (VM) Changes

CMS issued the 2015 Physician Fee Schedule Final Rule on November 13, 2014. The rule changes several of the quality reporting initiatives associated with PFS payments, including the Physician Quality Reporting System (PQRS). See Summary of CY 2015 finalized changes for CMS quality programs.


PQRS Reporting Requirements

Requirements to avoid the 2017 payment adjustment (-2.0%), based on 2015 reporting, are the same as for gaining the 2014 incentive with several additional requirements as identified below. 

Individual EP reporting requirements - 9 measures across 3 National Quality Strategy domains, for 50% of Medicare Part B FFS patients relevant to reported measures (or for 50% of ALL patients when using a Qualified Clinical Data Registry (QCDR), or, using a qualified registry, report 1 measures group for at least 20 patients (majority should be Medicare Part B FFS patients) with the following additional requirements:

  • Claims or qualified registry reporting: of the measures reported, report on at least one “cross-cutting” measure if the individual EP has seen at least one Medicare patient in a face-to-face encounter (based on these encounter codes). Reporting a cross-cutting measure(s) is not required when reporting a measures group. See cross cutting measure denominator coding. See information on 2015 PQRS Validation of Successful Reporting
  • QCDR reporting: of the 9 measures reported, report at least 2 outcome measures (vs 1 outcome in 2014) or if 2 outcome measures are not available, report 1 outcome measure and at least 1 resource use, patient experience of care, efficiency/appropriate use or patient safety measure. For more information on the ACR National Radiology Data Registry Qualified Clinical Data Registry click here.

GPRO reporting requirements - 9 measures across 3 National Quality Strategy domains, for 50% of Medicare Part B FFS patients relevant to reported measures with the following additional requirements :

  • Qualified registry reporting, groups of 2-99 EPs: of the measures reported, report on at least one “cross-cutting” measure if the individual EP has seen at least one Medicare patient in a face-to-face encounter (based on these encounter codes). See cross cutting measure denominator coding.
  • Groups of 2-99 also have the option to report all CAHPS for PQRS survey measures using a certified CMS survey vendor and at least 6 additional measures covering at least 2 National Quality Strategy domains using a qualified registry, with the same requirement to report one “cross-cutting” measure, or report 6 additional measures through EHR. If reporting CAHPS for PQRS Clinical/Group survey (measure #321), EPs will meet the one cross-cutting measure reporting requirement.
  • Groups of 100+ EPs: must report all the CAHPS for PQRS survey measures using a CMS certified survey vendor and at least 6 additional measures covering at least 2 National Quality Strategy domains using a qualified registry with the same requirement to report one “cross-cutting” measure, or report 6 additional measures through EHR. If reporting CAHPS for PQRS Clinical/Group survey (measure #321), EPs will meet the one cross-cutting measure reporting requirement.

PQRS Measure Changes

There are no new individual measures or measures groups relevant to radiology. All current measures remain available for 2015 PQRS, with the exception of measure #20, Perioperative care-timing of antibiotic. Be sure to review the new 2015 specifications for any changes to the measures.


2015 Measure Documents


2017 PQRS Payment Adjustments Based on 2015 Reporting

  • There is no PQRS incentive in 2015 and beyond. Also, the additional incentive for Maintenance of Certification is no longer available.
  • The 2017 automatic downward adjustment for not successfully reporting PQRS in 2015 is -2.0%. This penalty amount applies to all eligible professionals (EPs).

For more information on the 2015 Medicare Physician Fee Schedule (MPFS) Final Rule view presentation slides developed by CMS on December 2, 2014 here.


Value Based Payment Modifier

The value-based payment modifier applies to all physicians. The value modifier uses PQRS quality data and Medicare cost data to determine a provider's overall value score. It rewards high-performing providers with increased payments and reduces payments to low-performing providers. This will affect approximately 900,000 physicians. Payment adjustments may be applied if eligible providers (EPs) do not successfully report PQRS or through quality-tiering for those who do report PQRS . However for the 2015 reporting year/2017 payment adjustment year, solo providers and groups with 2-9 providers will not receive a VM penalty under quality-tiering, but may have a VM penalty if not reporting PQRS. Groups with 10 or more providers may receive an upward, neutral or downward adjustment under quality-tiering. See chart below for payment adjustment application.

2017 Value Modifier Penalty for 2015 PQRS Non-Reporters

Mandatory Quality-Tiering and Possible 2017 VM Payment Adjustment for Successful 2015 PQRS Reporters

  • Groups with 2-9 EPs and solo practitioners: Upward or neutral VM adjustment only based on quality-tiering (+0.0% to +2.0x of MPFS)
  • Groups with 10+ EPs: Upward, neutral, or downward VM adjustment based on quality-tiering (up to -4.0% to or +4.0x of MPFS)

How to Get Started with PQRS


PQRS Measures Relevant to Radiology


2015 PQRS Validation of Successful Reporting