In a small group? Combine with others now to participate in MIPS

Physicians in solo or small practices are potentially at a disadvantage when it comes to Medicare’s Merit-based Incentive Payment System (MIPS). They likely don’t generate enough patient data on their own to provide the significant statistics needed to fully participate in MIPS.

But the rules for the 2018 MIPS performance period include the optional ability for these physicians to create “virtual groups,” which allow them to pool their data and get on a more level playing field with larger group practices without the need to give up their independence.

The Centers for Medicare & Medicaid Services (CMS) says physicians have until Dec. 1 to formally notify Medicare that they have created and are participating in a virtual group.

As a reminder, CMS says a virtual group must combine two or more Taxpayer Identification Numbers (TINs) for a performance period of a year. These can include:

• A solo practitioner who’s eligible to participate in MIPS and bills under a TIN with no other National Provider Identifiers (NPIs) billing under the TIN, or
• A group with 10 or fewer eligible clinicians (at least one must be eligible for MIPS).

To form a virtual group, physicians can take one of two paths:

• Stage 1: Solo practitioners and groups with 10 or fewer eligible clinicians may contact their designated Technical Assistance representative or the Quality Payment Program Service Center to determine if they are eligible to join or form a virtual group.
• Stage 2: CMS will determine if the group members are eligible to join or form a virtual group. During Stage 2, the virtual group must name an official representative who will submit their election to CMS via email to MIPS_VirtualGroups@cms.hhs.gov by Dec. 1.

The virtual group election should include:

1. A written formal agreement between each of the virtual group members; and
2. Information about the TIN and NPI associated with the virtual group representative’s contact information.

For more information about joining or forming virtual groups, see the Virtual Groups Toolkit (third item down the page) available on the CMS web site. You can also contact the Quality Payment Program at QPP@cms.hhs.gov or 1-866-288-8292 (TTY: 1-877-715-6222).

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians