Small Practice Primer on Virtual Groups for MIPS

There’s relief in sight for small practices participating in the Merit-Based Incentive Payment System (MIPS). The first year of the program brought some challenges for small practices that did not have enough patients to get statistically valid quality measurement results. In 2018, small and solo practices who qualify for MIPS can now join a virtual group, and under one TIN provide statistically valid results on more measures.

The December 1, 2017 deadline to join a virtual group for MIPS 2018 is fast approaching. Here’s what you need to know:

What Is a Virtual Group?

A virtual group is a new way for solo practitioners or group practices with less than 10 MIPS-eligible clinicians to join together remotely to participate in MIPS and report their metrics across all four performance categories: quality, improvement activities, cost and advancing care information.

Virtual groups can consist of two or more providers who come together under appropriate classifications of providers, such as by geographic areas or by provider specialties. In other words, you can form a virtual group with other providers in your state or other providers with the same specialty as you who are submitting the same measures as your practice.

Once you join, you can’t leave the group during the performance period. This means you are locked in for a period of one year. Also, you can’t join more than one virtual group at a time.

A virtual group’s MIPS score is determined as a whole, and that score will affect reimbursement for all group members.

In order to participate, virtual groups must submit written notice of their election to CMS by December 1 of the year preceding the chosen performance period. To participate in a virtual group for MIPS reporting in 2018, you have until December 1, 2017 to form your group and submit your paperwork.

Who Can Participate in Virtual Groups?

As stated above, virtual groups are open to solo practitioners and groups with less than 10 clinicians. Solo practices must be MIPS-eligible to participate. Small group practices need to have at least one MIPS-eligible provider in order to join a virtual group.

Clinician types eligible for MIPS include:

• Physicians
• Physician assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Group that includes these clinicians

You can also participate in a virtual group if you are a solo practitioner, who has chosen not to participate in MIPS, if you:

• Exceed the low-volume threshold (That is, have greater than $90,000 in Medicare Part B allowed charges AND care for more than 200 Medicare Part B patients.)
• Are not a newly Medicare-enrolled eligible clinician
• Are not a Qualifying APM Participant (QP) or a Partial QP

Group practices that exceed the low-volume threshold at the group level are also eligible to join a virtual group.

What Are the Benefits of Participating in a Virtual Group?

One of the biggest benefits to joining a virtual group is the ability for smaller groups and solo practitioners to alleviate the practice risks inherent with smaller patient populations.

In a small practice, one patient with a bad outcome can severely affect your quality metrics. When you pool your risks through a larger group, it dilutes the affect of one bad outcome, potentially improving your quality metrics.

By some estimates, approximately 87% of solo practitioners will receive a penalty under MIPS, while large groups are expected to benefit from incentives.

Virtual groups allows solo and small practices to come together, share financial risk and work as a group towards a shared goal. By promoting joint accountability, you have a better chance at improving the cost, quality and experience of care.

Important Points to Consider Before Joining

Joining a virtual group is not without its risks and challenges. Choose your partners wisely. After all, your MIPS score will be a composite of all of the quality metrics from the providers in your group. Remember that you are locked into your virtual group for a full performance year.

With this in mind, be sure to do your research on the past Meaningful Use and Physician Quality Reporting System scores of potential partners. A good place to start is the CMS Physician Compare website to see whether a potential partner is using an electronic health record, whether he or she has participated in quality reporting and what their performance scores have been.

Each group will need a member who is willing to step up and lead the group. If you aren’t willing to take on the leadership role yourself, you will need to rely on the representative chosen by your group.

Also consider that since virtual groups are brand new, your group could face administrative and operational challenges since MIPS reporting will require a composite of the information from the different EHRs of all of the members. The good news is that to overcome this burden, CMS has offered virtual groups access to technical assistance from the QPP Service Center for the first two years (2018 and 2019).

How to Join a Virtual Group

There are four basic steps to creating a virtual group.

1. Check eligibility of members. Before you invest the time in the virtual group election process, all potential members should check their eligibility status. The easiest way to do this is for each provider or group to contact their designated technical assistance representative.
2. Gather information about each taxpayer identification number and national provider identifier associated with the virtual group.
3. Create a formal written agreement and designate representative. To make it easy, you can download the CMS’ 2018 Virtual Groups Toolkit, which includes a Virtual Group Agreement Checklist, a Virtual Group Agreement Template, information on the Virtual Group Election Process and a Virtual Group Participation Overview Fact Sheet.
4. Submit election to CMS. Your virtual group’s designated representative must submit the virtual group’s election via e-mail to MIPS_VirtualGroups@cms.hhs.gov. And, if anything changes in the virtual group, the representative must notify their designated CMS contact.

Source: CMS Quality Payment Program