CMS releases FAQ on 2019 MIPS payment adjustments, payment corrections to claims for Part B drugs
CMS recently posted answers in a set of Frequently Asked Questions (FAQ) about the 2019 Merit-based Incentive Payment System (MIPS) payment adjustment. The agency outlines the types of services subject to a 2019 MIPS payment adjustment, how these services are reflected on remittance advice (RA) documents, and anticipated payment corrections to claims billed for Part B drugs.
According to the FAQ, MIPS payment adjustments for calendar year 2019 will be applied to payments for covered professional services furnished by MIPS eligible providers. Payment adjustments won’t apply to Medicare Part B drugs and certain other items and services not covered by the Medicare Physician Fee Schedule (MPFS). CMS’ Physician Fee Schedule Look-Up Tool provides detailed information on services covered by the MPFS.
The FAQ also outlines the three RA code types for MIPS for claims with dates of service after January 1:
- Claim Adjustment Reason Codes (CARC)
- Remittance Advice Remark Codes (RARC)
- Group Codes
MIPS eligible providers receiving a positive payment adjustment will see the following line items and a corresponding amount: CARC 144 (incentive adjustment), RARC N807 (payment adjustment based on the MIPS), and CO (group code). Those receiving a negative adjustment will instead see: CARC 237 (legislated/regulatory penalty), as well as the N807 and CO codes.
Notably, the FAQ highlights an error CMS recently announced in the implementation of the 2019 MIPS payment adjustment: The agency incorrectly applied payments for certain Medicare Part B drugs and other nonphysician services billed by MIPS eligible providers.
According to CMS, the following corrective actions will be taken as a result of the error:
- If CMS overpaid a claim based on this error, the affected provider will receive a notification for recoupment from his or her Medicare Administrative Contractor (MAC)
- If CMS underpaid a claim based on this error, the provider can expect a payment adjustment
CMS assures affected providers that no action is required on their behalf. According to the FAQ, CMS has not set a date for the implementation of these payment corrections; however, the agency anticipates that it will make these adjustments soon.