2019 represents the first year of MIPS payment adjustments (which tie back to 2017 performance data). Practices may see a positive or negative adjustment on Part B services depending on their score and performance during the 2017 reporting year. The maximum adjustments for 2019 are +/-4 percent, although most practices will be closer to a neutral adjustment on either the positive or negative side. Adjustment Reasons associated with the incentives are 144 (incentive adjustment) or 237 (legislated/regulatory penalty). MIPS payment adjustments are required by law to remain budget neutral, making the positive adjustments equal to negative adjustments for the overall provider population. The resulting “scaling” will determine a practice’s/provider’s final adjustment percentage.
According to Section 1854(a)(6)(B)(iii) of the Social Security Act, CMS is prohibited from interfering in payment arrangements between Medicare Advantage Organizations and contracted providers. For this reason, whether and how the MIPS payment adjustments affect an MAOs payments to contracted providers are governed by the terms of the contract between the MAO and the clinician.
