MIPS Payment Adjustments

Deciphering 2019 MIPS payment adjustment remittance advice (RA) codes

2019 Merit-based Incentive Payment System (MIPS) adjustments based on your 2017 participation are now in effect.  These adjustments are applied to payments made for covered professional services furnished by a MIPS-eligible clinician (EC) in calendar year 2019. They do not apply to payments for Medicare Part B drugs or other items/services that are not covered professional services. When a 2019 MIPS payment adjustment is applied to a payment made to a MIPS EC, the following codes are displayed on your RA:

Positive ( + ) Adjustment

CARC 144

"Incentive adjustment, e.g. preferred product/service"

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.

Negative ( - ) Adjustment:

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.)"

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.

Frequently-asked questions

Q:  I received a positive payment adjustment for my 2017 MIPS, why am I seeing a negative adjustment?

A: One word:  sequestration.  We’ve gotten this question quite frequently recently, so wanted to provide a quick review of sequestration and how it affects the MIPS payment adjustments.

Q: Seques-what?

A: Sequestration is a mandatory payment reduction in the Medicare Fee-For-Service (FFS) program, set forth in the Budget Control Act of 2011.  This Act, among other things, requires mandatory across-the-board reductions in Federal spending, called “sequestration.”  Sequestration’s effective date was postponed in the American Taxpayer Relief Act of 2012. As required by law, President Obama issued a sequestration order on March 1, 2013.

Q: How long does it last?

A: The sequestration order covers all payments for services with dates of service, dates of discharge, or start date (for rental equipment or multi-day supplies) on or after April 1, 2013.   Medicare FFS payments will incur a 2% reduction (-2%), until further notice.  The claims payment adjustment are applied to all claims after determining coinsurance, any applicable deductibles, and any applicable Medicare Secondary Payment adjustments.

Q: How does it affect my MIPS positive adjustment?

A: When you see the CARC 144 and RANC N807 codes on your RA, you know you are receiving your positive payment adjustment for your 2017 MIPS participation.  However, due to sequestration, that positive adjustment may be displayed as a negative number. 

Resources:

2019 MIPS Payment Adjustment Fact Sheet, QPP.CMS.gov.  10/14/2018.

2019 MIPS Payment Adjustment FAQs and Resources, QPP.CMS.gov.  02/22/2019.

2019 MIPS Payment Adjustment Remittance Advice (RA) FAQs, QPP.CMS.gov.  11/05/2018.

Remittance Advice (RA) Information - An Overview, Medicare Learning Network.  October 2018.

CMS Medicare FFS Provider eNews, Medicare Learning Network.  03/08/2013.