2019 marks the first performance year for Medicare to pay incentive payments to eligible MIPS participants. Whether you are receiving an incentive payment or a penalty reduction, it is important to understand how to interpret the 2019 Medicare remittances you have started to receive.
All MIPS penalties and incentives are represented by unique adjustment reason codes. Medicare is using adjustment reason code CO 237 to label all penalties and code CO 144 to indicate an incentive payment. Medicare is not applying penalties or incentives to portions of the allowed amount that are patient responsibility. When a portion of the allowed amount is left for the patient to pay as part of their deductible or their coinsurance, Medicare deducts that balance prior to calculating any adjustments to your reimbursement amount.
Since Medicare is designating performance adjustments by utilizing specific reason codes, you can verify that your adjustment is accurate. Additionally, these adjustment reason codes also provide a method to track your adjustments in your practice management software.
To incorporate the MIPS adjustments into your processes, we advise the following:
- Check with your software vendors to ensure there are no processing problems with your 2019 Medicare remits.
- Access your Quality and Resource Use Report to confirm your score, and compare the expected adjustment to your remits for accuracy. The CMS website has instructions to guide you through accessing your QRUR reports.
- Work with your advisors to develop internal reports to effectively track and monitor your MIPS adjustments for the calendar year.