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Vast Majority of Pathologists to Avoid MIPS Penalties in 2020

Solutions provided by the CAP allowed pathologists to prevent a -5% penalty to their Medicare reimbursement in 2020. Based on quality reporting and other activities in 2018, the Centers for Medicare & Medicaid Services (CMS) reported that the vast majority of physicians and other clinicians eligible for Medicare’s Merit-based Incentive Payment System (MIPS) will not see their 2020 Medicare payments negatively adjusted.

For pathologists, the CAP’s quality measures were largely used to stop penalties that save pathology practices tens of millions of dollars annually. Also, for 2018, the CAP offered its Pathologists Quality Registry as a tool to stop the MIPS penalty and optimize reimbursement. The CAP further provided guidance to its members on, for example, which MIPS improvement activities were most likely relevant to their practices.

Key statistics reported by the CMS on January 6 are:

  • 98%, or about 872,150, of MIPS-eligible clinicians will receive a neutral or positive adjustment in 2020.
  • 5% negative adjustments will be levied on 2%, or about 17,800, of MIPS-eligible clinicians in 2020.
  • 1.68% is the maximum positive adjustment in 2020 for exceptional performance in MIPS. The positive payment adjustment is modest because, under statute, the positive and negative payment adjustments must be budget neutral. This means funds available for positive payment adjustments are limited to the estimated decrease in payments, according to the CMS.

The 2020 MIPS payment adjustments will be reflected on remittance advice documents for your Medicare Part B services. Share with your practice administrators that positive MIPS payment adjustments will be denoted by claim adjustment reasons code (CARC) “CARC 144” and remittance advice remark code (RARC) “RARC N807.” If you are being penalized, you will see “CARC 237” on the remittance advice.

If you need support on understanding these adjustments or have questions about using the Pathologists Quality Registry at your practice, contact the CAP’s experts at mips@cap.org.

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