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2022 MIPS Payment Adjustments


CMS MIPS HHS

2022 MIPS Payment Adjustments Have Begun!

All claims billed with DOS starting 1/1/2022 will reflect your MIPS payment adjustment. Your payments for services in 2022 will be adjusted based on your MIPS score in 2020. 

Some important notes:

  • Covered professional services, which exclude drugs and other items that aren't services, will be adjusted in the Medicare Paid amount on your remittance advice (RA).
  • It does not impact the amount that they patient pays, so do not adjust copays or deductibles. If the patient hasn't met their deductible, there will be no payment adjustment since you will receive no payment.
  • Only MIPS Eligible Clinicians (ECs) will have a payment adjustment. 
  • Adjustments are applied to Traditional and Railroad Medicare Part B. 
  • Medicare Advantage Organizations (MAOs) have different rules for contract and non-contract MIPS ECs:
    • Contract: Whether and how the MIPS payment adjustments affect MAO payments to its contract clinicians are governed by the contract terms between the EC's and the MAO.
    • Non-Contract: MAOs are required to apply positive MIPS payment adjustments in to covered professional services, application of any negative MIPS payment adjustment is at the discretion of the MAO.

What you will see in your Remittance Advice (RA):

  • CARC 144: "Incentive adjustment, e.g. preferred product/service" [positive adjustment]
    -or-
    CARC 237: "Legislated/Regulatory Penalty. At least one Remark Code must be provided (may be comprised of either the NCPDP Reject Reason Code, or Remittance Advice Remark Code that is not an ALERT.)" [negative adjustment]
  • RARC N807: "Payment adjustment based on the Merit-based Incentive Payment System (MIPS)."
  • Group Code: CO. This group code is used when a contractual agreement between the payer and payee, or a regulatory requirement, resulted in an adjustment.

Important next steps:

  • If you are a MarsdenAdvisors client, keep an eye out for an email next week which will contain information about your specific adjustment.
  • Share this information with your billing staff so that they are prepared to look for these adjustments. They may also find this MIPS Fact Sheet helpful.
  • Reach out to your practice management system vendor and ask for guidance on setting up the payment posting section to handle these adjustments. The paid amount should not result in a negative patient balance nor reduce the responsibility of the next payer or patient. Otherwise you may lose your bonus amount.
  • If you receive a CARC 237 on any claims, notify us. This is a penalty and we are not expecting this to be happening.

If you have any questions on this, let us know! 

Jessica Peterson

Written by Jessica Peterson

Jessica Peterson, MD, MPH is the Vice President of Health Policy at the consulting firm MarsdenAdvisors.

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