The payment adjustments from the 2017 Performance Year of the Quality Payment Program (QPP) are being applied to the 2019 dates of service and are showing up in ERA files and on EOBs in physician offices around the country. Please check your EOBs!
As you are reviewing your 2019 Medicare Part B payments, be aware of the following:
New and updated CARC and RARC codes are being used
Positive MIPS payment adjustments are designated as 144 Incentive adjustment and N807 Payment adjustment based on MIPS.
Negative MIPS payment adjustments are displayed on RAs as 237 Legislated/Regulatory Penalty
If you did not submit data in 2017, you may see a four percent negative adjustment (shown as a positive amount on your EOB).
Positive payment adjustments are indicated as a negative adjustment on your EOB.
Part B drugs and supplies are not subject to any payment adjustments (positive or negative).
An example of how the adjustments are applied to payments is shown in the chart below.
Novitas Solutions, the Jurisdiction H Medicare Administrative Contractor (MAC), is responsible for Part B payment processing but the methodology for applying the payments is regulated by CMS. (NOTE: CMS is aware that Novitas Solutions has been applying adjustments to Part B drugs in error. They will recoup any overpayments.)
You don't have to have an EHR to avoid a penalty or earn a positive adjustment or bonus.
It does not cost you any money to submit data.
You can now check your 2019 eligibility on the QPP website!
If you are an eligible clinician, a LAMMICO insured and have not already implemented a process for capturing or reporting MIPS data in your practice, contact LAMMICO and let us help you! If you already have a MIPS process, we can be an additional resource and discuss options regarding MIPS.
There is no charge for our consultation. These services are provided to you because you are a LAMMICO insured.
Participation in the Quality Payment Program may also help you mitigate your malpractice risk through tracking and improving quality care (Quality measures), increasing patient engagement and satisfaction (Improvement Activities) and improving communications using secure electronic transmissions between providers and with patients (Promoting Interoperability).
Here are some other CMS resources:
MIPS Payment Adjustment Remittance Advice FAQ
2019 MIPS Payment Adjustment for 2017 Performance Year Infographic
Fact Sheet: 2019 MIPS Payment Adjustments based on 2017 MIPS Scores
MIPS Payment Adjustment Example
Please note: In this example, the physician only earned a small positive payment adjustment of 0.15% in 2017. Although the $0.12 adjustment may not seem worth the effort of reporting data, if this same provider had not submitted any data, the penalty would have been -4%. Using this same example, the provider would have been penalized $3.09 for this one service. Remember, the MIPS adjustment is calculated on all Part B Professional Services. The financial impact can be significant.
If you have any questions or need additional information, contact LAMMICO Practice Management Specialist, Natalie Cohen, MBA, MHA, at 504.841.2727 or email@example.com.