Q: I’m a MIPS eligible clinician who billed under multiple TINs during the 2020 MIPS performance year. Could I have multiple payment adjustments in 2022?
A: Yes. If you were MIPS eligible under multiple TIN/NPI combinations, you may receive a distinct MIPS payment adjustment for covered professional services furnished in 2022 and billed under each of those TIN/NPI combinations.
Q: Is the 2022 MIPS payment adjustment applied before or after sequestration?
A: Before sequestration. Sequestration is the automatic reduction in Medicare fee-for-service (FFS) payments to plans and providers, resulting from the Budget Control Act of 2011. The MIPS payment adjustment percentage is applied to the Medicare paid amount for covered professional services furnished by a MIPS eligible clinician after calculating deductible and coinsurance amounts but before sequestration.
Q: Is the 2022 MIPS payment adjustment applied to the Medicare paid amount or Medicare allowed amount?
A: The MIPS payment adjustment is applied to the Medicare paid amount for covered professional services (services for which payment is made under, or is based on, the Medicare Physician Fee Schedule) furnished by a MIPS eligible clinician.
Q: Do 2022 MIPS payment adjustments impact Medicare Advantage payments to in-network/contracted providers? If so, how?
A: Section 1854(a)(6)(B)(iii) of the Social Security Act prohibits CMS from interfering in payment arrangements between MAOs and contracted clinicians by requiring specific price structures for payment. Thus, whether and how the MIPS payment adjustments might affect an MAO’s payments to its contracted clinicians are governed by the terms of the contract between the MAO and the clinician. Additional guidance is contained in April 27, 2018 HPMS Memo entitled “Application of the Merit-based Incentive Payment System (MIPS) Payment Adjustment to Medicare Advantage Out-of-Network Payments.”
Q: How will 2022 MIPS payment adjustments be reflected on remittance advice (RA) documents?
A: If a 2022 MIPS payment adjustment is applied to a payment made to a MIPS eligible clinician, the following codes will be displayed on the RA6:
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