CMS Announces the 2018 Virtual Groups election period under MIPS is open

CMS announced recently that the “Virtual Groups” option put forth in the original MIPS/MACRA legislation is now open for 2018 MIPS.  This option was not available for 2017 MIPS.  In a posting in the CMS “MLNConnects” for October 19, 2017, CMS notes:

The election period is open to form a virtual group for the 2018 Merit-based Incentive Payment System (MIPS) performance period. As proposed in the 2018 Quality Payment Program proposed rule, solo practitioners and groups can choose to participate in MIPS as a virtual group for the 2018 performance period through an election process through December 1, 2017.

You can link to the information in the CMS news release here.  Scroll down to the “MIPS Virtual Group Election Period” area and you will note that CMS has some resources that might be helpful – particularly the “Virtual Groups Toolkit”.  One of the documents in the Toolkit is a sample formal written agreement that each NPI and TIN execute.  CMS has already noted in the 2018 QPP Proposed Rule “… As proposed … solo practitioners and groups with 10 or fewer eligible clinicians who participate in … (MIPS) as a virtual group … have to execute a formal and contractual written agreement. This agreement would have to be completed by each virtual group member and … [applies to] at least 1 performance period.”

A “Virtual Group” is made up of two or more TIN and is only available for solo practitioners or those groups with 10 or fewer eligible clinicians (if 1 or more in the small group is eligible under MIPS).  The partnering clinicians/TINs do not have to be made up of providers in the same specialty, so ophthalmologists or optometrists could virtually partner under MIPS with other specialties to help each other with certain tasks in MIPS that each one alone might otherwise find difficult to meet.

Importantly, a Virtual Group requires establishment of another TIN for purposes of MIPS.  CMS notes that during the formation of the Virtual Group, “each of the virtual group’s members [need] to update their Medicare enrollment information, including adding and deleting NPIs billing through a TIN that’s part of a virtual group. The updates have to be made in accordance with Medicare program requirements …”.  They also note If an NPI joins or leaves the [MIPS Virtual Group] TIN, or a change is made to the TIN that changes the agreement itself (e.g., a legal business name change) during the … performance year, a virtual group has to update the agreement and send the changes to the [QPP] Service Center.”

The current deadline is fast approaching but the professional societies have reached out to CMS in hopes of extending the deadline past December 1, 2017.

Please contact us for help with MIPS or other coding, documentation, or concerns via one of the below or on our “App”, Corcoran 24/7, which can be accessed via one of the bottom links.

www.corcoranccg.com (800) 399-6565

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