The 2019 Virtual Group Elelction Period is now open. All contracting must be complete by December 31, 2018.
You can participate in a virtual group if you’re a:
Virtual groups can be comprised of any type of group, no matter where the clinicians practice or their specialty type.
A solo clinician or group can only participate in one virtual group in any performance period. But, there are no limits on how many solo practitioners and groups can join a virtual group.
If a group chooses to join a virtual group, all eligible clinicians in that group have to be included in the virtual group. Any group that wants to be part of a virtual group must have 10 or fewer eligible clinicians.
All TINs will be scored together as part of the virtual group, but only the clinicians within the various TINs who are eligible for MIPS can get a MIPS payment adjustment. TIN sizes are based on how many NPIs bill under a TIN, including the clinicians who don’t meet the definition of a MIPS eligible clinician (listed above) as individuals and can’t participate in MIPS.
When eligible clinicians and groups want to form a virtual group, they have to go through the election process. The election to participate in MIPS as a virtual group has to happen before the performance period and can’t change during the performance period. For the 2018 MIPS performance period, the election period began on October 11, 2017, and ended on December 31, 2017, but clinicians should consider whether to elect in future years.
There is a 2-stage election process for virtual groups:
Stage 1 (optional): If you’re a solo practitioner or part of a group with 10 or fewer eligible clinicians, you can choose to contact your Quality Payment Program Technical Assistance representative. Your representative can help you determine whether you're eligible to join or form a virtual group prior to starting any of the other requirements.
To be eligible to form or join a virtual group, solo practitioners have to:
To be eligible to form or join a virtual group, groups have to:
Stage 2 (required): As part of the stage 2 election process, a virtual group must have a
formal agreement between each solo practitioner and group that composes the virtual group prior to submitting an election to CMS. Each virtual group has to name an official representative who is responsible for submitting the virtual group’s election via e-mail by December 31, 2017.
CMS will then confirm whether or not each TIN within a virtual group is eligible to participate in MIPS as part of a virtual group; identify the NPIs within each TIN participating in a virtual group that are excluded from MIPS in order to ensure that such NPIs would not receive a MIPS payment adjustment; calculate the low-volume threshold at the individual and group levels; and notify each virtual group’s official representative as to whether or not their virtual group is considered an official virtual group for the applicable performance period.
While it is understood that TIN sizes might change after virtual groups are approved by CMS, TIN size determinations that are made for virtual group eligibility during the 2-stage election process will remain valid for the whole performance year.
A virtual group must have a formal written agreement between each solo practitioner and group that composes the virtual group, which ensures that everyone understands and agrees with MIPS participation requirements. To support this process, CMS has created a Virtual Groups Model Agreement to serve as a template that virtual groups can use, and to which they can add other elements that would meet the particular needs of the virtual group.
Virtual groups will have their performance assessed and scored at the virtual group level across all four performance categories: Quality, Improvement Activities, Advancing Care Information and Cost. Each TIN/NPI in the virtual group will earn a final score based on the virtual group’s performance. However, only MIPS eligible clinicians will receive a MIPS payment adjustment based on the virtual group final score. New Medicare-enrolled eligible clinicians and clinician types not included in the definition of a MIPS eligible clinician who are associated with a TIN that is part of a virtual group will receive a virtual group score, but will not receive a MIPS payment adjustment.