Time to form virtual groups for the MIPS 2019 performance year

If you’re interested in forming a virtual group for the 2019 Merit-based Incentive Payment System (MIPS) performance year, the election period is now open. These groups can eliminate some of the disadvantages solo and small practices may potentially face when complying with MIPS.

To form a virtual group, you must follow the election process described below and submit your election to the Centers for Medicare & Medicaid Services (CMS) by Dec. 31.

Who can join a virtual group? You can participate in a virtual group if you are either:

1. A solo physician who is eligible for MIPS and exceeds the low-volume threshold; is not newly enrolled in Medicare; does not participate in an Alternative Payment Model (APM); and is not a partial qualifying participant (QP) choosing not to participate in MIPS; OR

2. A group with 10 or fewer eligible clinicians (at least one of whom must be MIPS-eligible) that exceeds the low-volume threshold at the group level and whose members have reassigned their billing rights to the Taxpayer Identification Number (TIN).

Please note: TIN size is based on the total number of clinicians, or National Provider Identifiers, billing under a TIN, which includes clinicians who are and are not MIPS-eligible.

There is a two-stage election process for forming a virtual group:

Stage 1 (optional):

• Contact your Quality Payment Program Technical Assistance organization to help determine if you meet the TIN size criteria to join or form a virtual group.

Stage 2 (required):

• Have a formal written agreement between each of the virtual group members;
• Name an official virtual group representative;
• Submit the virtual group’s election via e-mail to CMS at MIPS_VirtualGroups@cms.hhs.gov by Dec. 31; and
• Determine if you meet the TIN size criteria and exceed the low-volume threshold.

You can download the 2019 Virtual Groups Toolkit to learn more about the election process and how to participate in MIPS as a virtual group for the 2019 performance year. The toolkit also contains sample templates for the submission e-mail and the virtual group formal agreement. You can choose the size and composition of your virtual group, and your virtual group may be formed based on location, specialty, or shared patient population.

To support the establishment and implementation of virtual groups, free, one-on-one technical assistance is available upon request from on-the-ground organizations. You can also contact the Quality Payment Program with questions by:

• Email: QPP@cms.hhs.gov or
• Phone: 1-866-288-8292/ TTY: 1-877-715-6222

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