Virtual groups (VGs) were included in the MACRA statute to help solo and small practices successfully participate in MIPS.
Solo practitioners and practices with 10 or fewer national provider identifiers (NPIs) billing under the same tax identification number (TIN) are eligible to join a VG. The group size calculation includes non-MIPS eligible clinicians (ECs).
If joining a VG, all ECs within the group must participate, even those below the low-volume threshold. However, ECs excluded from MIPS would not be subject to payment adjustments.
You can contact your local QPP technical assistance organization or the QPP Service Desk for assistance in determining if you are eligible.
Virtual groups must consist of at least two TINs. VGs must designate one VG representative to be the main point of contact for the group.
Participants must establish a written formal agreement and each member of the VG must retain a copy of the agreement. The agreement is binding for the entire performance period.
Virtual group elections must be made annually before the applicable performance period. The deadline to make elections for the 2019 performance period was December 31, 2018. The deadline for the 2020 performance period is December 31, 2019. The election period should open in September.
Virtual groups are assessed as a group across all four performance categories and all VG MIPS-eligible clinicians will receive the same final score. VGs are responsible for aggregating data for submission to the Centers for Medicare & Medicaid Services (CMS). CMS will not aggregate data for VGs.
Access the CMS Virtual Group Toolkit in the QPP resource library.