Now Open: Virtual Group Election for MIPS Participation

Solo, Small Practices Can Band Together to Mitigate Risk

October 17, 2017 04:24 pm Sheri Porter

(Editor's Note: According to the 2018 Quality Payment Program final rule( put on public display as of Nov. 2 and scheduled to be published in the Federal Register on Nov. 16, the virtual group participation election deadline has been extended to Dec. 31.)

CMS recently announced that solo and small group practices have until Dec. 1 to tell the agency they are electing to participate in a virtual group -- a reporting option available to practices as outlined in the 2018 Quality Payment Program (QPP) proposed rule.(  

That means solo family physicians or group practices with 10 or fewer clinicians who are eligible participants in the Merit-based Incentive Payment System (MIPS) and want to form a virtual group for 2018 must act quickly.

A good first step for physicians who are interested in the virtual group option would be to download CMS' virtual groups toolkit.( Three documents are included in the kit: a virtual group agreement checklist, an agreement template and details about the election process.

Amy Mullins, M.D., the AAFP's medical director of quality improvement, told AAFP News that the Academy has championed the concept of virtual groups because they offer a better chance for a positive MIPS experience among small practices that want to remain independent.

She stressed that the option is not a financial agreement, and it does not meet the criteria for an accountable care organization; rather, it represents a "banding together for reporting purposes to be more successful in MIPS."

"The larger the sample on quality -- meaning the larger the group -- the better the quality metrics potentially could be," said Mullins.

In other words, she explained, "If you get together with others and pool your risk, then one patient with a bad outcome will not affect your measurement in such a large way."

If a virtual group sounds appealing, "Start thinking about who you could band together with, but make wise choices, because you will be reporting as a group and getting a group score," Mullins added.

She noted that physicians can go to the CMS Physician Compare website( to see whether a colleague is using an electronic health record and whether he or she is has participated in quality reporting. "And then you need to have an honest discussion with that physician about quality levels," said Mullins.

"Keep in mind that your colleague down the street may have a really good golf score, but his score on diabetes may not be as great," she cautioned.

Mullins advised physicians to do a quick check of their eligibility status before investing additional time in the virtual group election process. They can contact their designated technical assistance representative( or connect with the national QPP Service Center by email or by phone at (866) 288-8292.

After making that determination, family physicians can then decide whether a virtual group is right for them.

CMS clarified that each virtual group must have a formal written agreement among all group members, as well as information about each taxpayer identification number and national provider identifier associated with the virtual group.

The agency also noted that these proposed policies could change when the QPP 2018 final rule is released, which is scheduled to occur before Nov. 1.

Stay tuned to AAFP News for updates.

Related AAFP News Coverage
AAFP Urges Changes in 2018 Quality Payment Program Proposal
MIPS Performance Period, Measures, Cost Weighting Among Top Concerns

AAFP Leads Effort to Halt Proposed QPP Changes
Move to Increase Low-volume Threshold for MIPS Draws Ire

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