Update March 4: The Centers for Medicare & Medicaid Services (CMS) has acknowledged the error that TMA identified in MIPS payment adjustments applied to Medicare Part B drugs, and is working to resolve the issue.
“At this time, CMS is unable to provide an exact date of when impacted clinicians will see the update and correction, but we anticipate an adjustment in the near future,” CMS said in an FAQ on its website. “In the event that CMS overpaid a claim based on inclusion of the Medicare Part B drugs, a notification for recoupment will be issued from their MAC (Medicare Administrative Contractors) on behalf of CMS.”
The Texas Medical Association reminds physicians and practices not to submit refunds until they receive a request from Novitas, Texas’ MAC, nor should they resubmit claims to be processed.
TMA will keep you informed when refund letters will start being delivered.
Original Story: If it’s not something you do regularly, TMA recommends you take a close look at your 2019 Medicare payments.
Payment adjustments for Medicare’s Merit-Based Incentive Payment System (MIPS) under the Quality Payment Program (QPP) have begun, but an error has been reported to the Texas Medical Association.
MIPS payment adjustments apply only to covered professional services payable under the Medicare physician fee schedule. They do not apply to new Medicare-enrolled eligible clinicians. And because of TMA and organized medicine advocacy, they should not apply to Medicare Part B drugs or other items and services that are not covered professional services.
However, practices have reported seeing MIPS payment adjustments applied to Medicare Part B drugs. TMA has contacted Novitas, Texas’ Medicare Administrative Contractor, and the Centers for Medicare & Medicaid Services (CMS) about this error. TMA will provide you with more information as soon as we know how CMS will handle these errors. At this time, practices do not need to contact Novitas about this error.
According to CMS, based on 2017 performance results, the maximum positive adjustment (bonus) in 2019 is 1.88 percent and the maximum negative adjustment (penalty) is 4 percent. The percentage of your payment adjustment should be what is displayed in your 2017 MIPS performance feedback report located in the QPP portal.
If you expect to receive a MIPS bonus or penalty this year, TMA recommends you check your claims remittance advice (RA) to ensure accurate payment.
Here is how to tell whether you are receiving a MIPS payment adjustment:
- After you submit a claim to Novitas, you will receive an RA that explains your payment and any adjustment made during Medicare’s claims adjudication process, among other details.
- When you receive your RA, look for these three code types: 1) claim adjustment reason codes (CARC); 2) remittance advice remark codes (RARC); and 3) group code.
- Codes for a positive adjustment are CARC 144 (incentive adjustment), RARC N807 (MIPS payment adjustment), and group code CO. Codes for a negative adjustment are CARC 237 (legislated/regulatory penalty), RARC N807 (MIPS payment adjustment), and group code CO
Physicians who are non-participating with Medicare and file unassigned claims do not need to calculate the MIPS adjustment into the amounts they may collect from a patient. In previous years, Novitas had posted a fee schedule to help physicians calculate penalties for the adjusted limiting charge. Starting in 2019, CMS decided to NOT apply the MIPS payment adjustment to any non-assigned claims. You can reference the regular fee schedule on the Novitas website for information on the limiting charges for services.
For complete details about the 2019 MIPS payment adjustment, refer to this CMS infographic, remittance advice FAQ, and fact sheet. For questions, contact the QPP Service Center at (866) 288-8292 or by email at QPP[at]cms[dot]hhs[dot]gov.
The other option under the QPP is the alternative payment model (APM) track. Physicians who participated in an advanced APM and achieved qualified participant status in 2017 will receive the 5-percent bonus in the form of a lump sum incentive payment, not via individual payment adjustments. These physicians should check with their APM administrator for details.
As always, visit the TMA MACRA Resource Center to stay up to date on the QPP.