You might be able to boost your future MIPS bonus score by forming a MIPS virtual group, but you have only until Dec 31 to do so.
Not sure what this option is and if it’s right for you? Now’s the time to get your ducks in a row and decide if this option will financially benefit you and your practice.
These answers to the most common MIPS virtual groups Q&As will get you started.
Q: What Is a MIPS Virtual Group?
A virtual group is a group of two or more groups that band together to report for MIPS. It’s intended to make it easier for small practices to participate and perform well in MIPS.
It’s one of the three ways that clinicians can participate in MIPS (the other two ways are as an individual or a regular group).
Key term: A group is defined as all the clinicians who are under the same TIN (Taxpayer Identification Number).
Q: How Do I Know If My Practice Is Eligible to Join a MIPS Virtual Group?
Groups of 10 or fewer clinicians (including solo practitioners) can join virtual groups provided one of the clinicians is eligible to participate in MIPS. This includes solo practitioners who are eligible to participate in MIPS.
CMS determines a TIN’s eligibility to join a virtual group using claims data from the period Oct. 1, 2018, through Sept. 30, 2019.
For a practice’s MIPS performance to be scored at the virtual group level, the clinicians participating in the virtual group must meet the requirements of a virtual group for the entire performance period (Jan. 1, 2020 to Dec. 31, 2020).
For instance, you would disqualify if you are part of a virtual group of two practices, and the other practice becomes eligible for the APM track and opts into that disbanding from the virtual group.
If you’re not sure if your practice meets the size requirements, you can check with your local technical assistance provider. These are providers who give personal assistance (at no cost) with the QPP to small, rural, and undeserved practices.
Tip: If you are a solo practitioner or group who meets at least one of the low volume threshold requirements and wants to join a virtual group, you do not need to do a separate opt-in to MIPS. Your election to join the virtual group automatically serves as your opt-in.
Q: How Do I Apply to Join a MIPS Virtual Group?
You must apply via email on or before Dec. 31, 2019, to join a virtual group for the 2020 MIPS performance period. The application will be submitted by a “virtual group representative,” a person the group has selected. The application process has some steps:
1: Verify your group (TIN) meets eligibility requirements for a virtual group.
2: Identify an official representative for the group. This is the person who will submit the virtual group application.
3: All participating practices in the virtual group must have a formal written agreement between each group/solo practitioner who is part of the virtual group. You don’t need to submit the agreements with the election, you must attest that you have them.
4: The official representative submits the election via email prior to the deadline.
CMS will then approve or deny your election. Decisions are made on a rolling basis, so the earlier you submit your election, the earlier you’ll get a decision.
Q: I’ve Been Chosen as My Virtual Group’s Official Representative. What Do I Do Now?
The official representative is responsible for submitting the virtual group election to CMS. You must include the following information:
- Your name, TIN/practice affiliation, and contact information
- The TIN and business name (as recorded in PECOS) for each TIN in the virtual group. If a TIN is the Social Security number of the provider, only list the last six digits.
- The name and NPI of each provider associated with each TIN.
- Attest to having a formal, written agreement from each TIN in the virtual group.
Q: What MIPS Virtual Group Reporting from TIN Differences Exist?
All the measures and activities are the same for a virtual group as for a regular group. However, with the virtual group, the group must aggregate its data across the group (across each TIN).
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