On Oct. 11, the Centers for Medicare and Medicaid Services (CMS) opened the “virtual group” election period for participation in the 2018 Merit-based Incentive Performance System (MIPS) performance year. Clinicians have from now until Dec. 1, 2017, to make an election. This process was set in motion following introduction of the virtual group participation option in the proposed rule for the 2018 Quality Payment Program. Virtual groups are solo practitioners and groups of 10 or fewer eligible clinicians who come together virtually for participation in MIPS for one performance year. More specifically, virtual groups can be a combination of two or more Taxpayer Identification Numbers (TINs) made up of:
- A solo practitioner who is eligible to participate in MIPS and bills under a TIN with no other National Provider Identifiers (NPIs) billing under the TIN
- A group with 10 or fewer eligible clinicians (at least 1 must be eligible for MIPS) that joins with at least 1 other solo practitioner or group for a performance period of a year.
CMS has proposed a two-stage process for virtual group elections. In Stage 1, solo practitioners and groups with 10 or fewer eligible clinicians contact their Technical Assistance representative or the Quality Payment Program Service Center to determine if they are eligible to form a virtual group. Groups that do not participate in Stage 1 may still proceed to Stage 2. In Stage 2, the virtual group names an official representative to submit their group’s election to CMS via email to MIPS_VirtualGroups@cms.hhs.gov by Dec. 1, 2017.