In Year 2 of the Quality Payment Program (QPP), CMS has introduced a new quality reporting option for solo practitioners and small group practices to participate in MIPS quality reporting. Virtual Groups provide solo-practitioners and small group practices all the advantages of group reporting without the need to be in the same group practice or physical location. Small group practices, for the purposes of Virtual Groups, are defined as 10 or fewer eligible clinicians.
Virtual Group Requirements
The virtual group must be approved by CMS and applications are due by December 31 of the year prior to the performance year. For 2018, this means applications were due by December 31, 2017; probably far too short a time-frame for practical purposes to form a Virtual Group for 2018.
While there is no limit to the number of providers that can be in a virtual group, any one practice as defined by Tax Identification Number (TIN) cannot have more than 10 clinicians and as a group, cannot be below the low-volume threshold. In 2018, this threshold is $90,000 in Medicare Part B claims or 200 Medicare patients.
There is a two-stage election process. The first stage is optional and helps you decide if you are eligible to form a Virtual Group. This determination is made with the assistance of a CMS Technical Assistance organization. We recommend taking advantage of this assistance to that you don’t waste time forming or joining a group. Stage 2 is forming the group through registration, eligibility determination, and documentation.
To assist in this process, CMS also posted a Virtual Groups Toolkit.
Working Together Could Bring Some Benefits
There are some distinct advantages to reporting as a Virtual Group for certain practices: Specialists reporting alone, may not have enough volume on a measure for statistically meaningful results. Working in a Virtual Group with other specialists could overcome that barrier.
Virtual Groups could be ideal for Independent Practice Associations (IPA) who are already sharing services and an electronic health record. Reporting together could decrease the level of effort required for all members.
Virtual Groups can help small practices maintain their independence by using a collaborative model which encourages clinicians and practices to connect with each other in a virtual community where they can learn from each other’s talents and expertise.
On the flip side though, if someone is participating successfully in MIPS with high scores, they would need to carefully review any Virtual Group partners to make sure that everyone would succeed under a Virtual Group model of MIPS reporting. Unlike other groups, if someone is in a Virtual Group, they forgo the option to report as an individual. CMS will not take the higher of the two scores.
While there are some challenges to overcome with the inclusion of Virtual Group participation for 2018, Mingle Health believes this could be an exciting new concept in quality reporting, one that has the potential to provide numerous opportunities to solo practitioners and small groups to improve cost and quality of care, ultimately improving the overall operations of each participant.
Interested in how Mingle Health can help you succeed in MIPS and the Quality Payment Program? Contact us today, our knowledgeable and friendly consultants are eager to help guide you to submission success!
Looking for more 2018 Quality Payment Program resources?
Curious about the other changes ahead for Medicare quality reporting as outlined in the 2018 Final Rule? Check out our blog post, Key Highlights from the 2018 QPP Final Rule. You can also watch these recorded webinars, presented by Dr. Dan Mingle, quality reporting expert, and CEO of Mingle Health:
Dr. Dan Mingle shares key changes to MIPS from the 2019 Final Rule.