Medicare’s final rule provides a new opportunity for solo practitioners and small groups to join together and report as a virtual group. For small groups interested, the deadline to elect a virtual group is December 31, 2017 for the upcoming 2018 performance period.
What is a Virtual Group?
Medicare defines a virtual group as a combination of two or more Taxpayer Identification Numbers (TINs), representing solo practitioners and groups of ten or fewer clinicians who come together “virtually”, regardless of specialty or location, to participate in MIPS for a performance period. Each TIN joining has at least one Merit-based Incentive Payment System (MIPS) eligible clinician. A solo practitioner or group can only participate in one virtual group per performance period, but there are no limits to the number of entities that form a virtual group.
Why Virtual Groups?
The addition of virtual groups in year two of MIPS extends some benefits to those practitioners who are included in the program but may not have the same technology and staff resources to be competitive. Achieving a high score in relation to others means receiving an incentive as opposed to a negative payment adjustment. Medicare provided assumptions in MACRA 2015 that noted solo and small groups were more likely to receive negative payment adjustments, while larger groups were more likely to receive positive payment adjustments. By allowing virtual groups, the thought is to give some benefits to the smaller classes.
How Does My Practice Qualify as a Virtual Group?
Because the groups are otherwise independent of each other, notification must be provided to Medicare before the December 31, 2017 deadline of the virtual group’s formation. Interested practitioners should review the full details and qualifications of the program. Medicare has assigned Quality Payment Program Technical Assistance organizations by state if practitioners need additional resources. Requirements include the following:
- Formal written agreement between all members
- Virtual group representative chosen who will submit the election via email to CMS at MIPS_VirtualGroups@cms.hhs.gov
- Provide TIN and NPI associations for the group
- CMS reviews the virtual group’s low-volume threshold by reviewing its claims. It also verifies group eligibility for the number of practitioner NPIs associated with the small group’s Taxpayer Identification Number. A TIN with the ten or fewer practitioners accepted into the virtual group by CMS will remain in the virtual group for the performance period even if the group’s size changes during that time
For help navigating the Quality Payment Program or forming a Virtual Group, contact the Anders Health Care Group.
