December Fast Facts from the CoQPP Coalition
1. Who can join a virtual group?
A Virtual Group is a combination of two or more Taxpayer Identification Numbers (TINs) made up of solo practitioners and groups of 10 or fewer eligible clinicians who come together “virtually” (no matter specialty or location) to participate in MIPS for a performance period of a year.
2. How are virtual groups treated?
The policies that apply to groups generally apply to virtual groups, but note that:
The definition of a non-patient facing clinician includes eligible clinicians in a virtual group if more than 75 percent of NPIs billing under the virtual group’s TINs meet the definition of a non-patient facing individual MIPS eligible clinician during the non-patient facing determination period. Virtual groups determined to be non-patient facing will have their Advancing Care Information performance category automatically reweighted to 0. For the 2018 MIPS performance period, the quality, improvement activities, cost and advancing care information performance category scores will be given weight in the final score, or be reweighted if a performance category score is not available.
- A virtual group will have a small practice status if the virtual group has 15 or fewer eligible clinicians.
- A virtual group will be designated as a rural area or Health Professional Shortage Area (HPSA) practice if more than 75 percent of NPIs billing under the virtual group’s TINs are designated in a ZIP code as a rural area or HPSA.
- Virtual groups participate in MIPS across all four performance categories, and are subject to the same measure and performance category requirements as other groups reporting under MIPS. Virtual groups can submit data the same ways groups can. Each virtual group would aggregate its data across its TINs for each performance category and be assessed and scored at the virtual group level.
3. Can a virtual group qualify for small or rural considerations?
A virtual group will have a small practice status if the virtual group has 15 or fewer eligible clinicians. A virtual group will be designated as a rural area or Health Professional Shortage Area (HPSA) practice if more than 75 percent of NPIs billing under the virtual group’s TINs are designated in a ZIP code as a rural area or HPSA.
4. How do I join a virtual group?
When eligible clinicians and groups want to form a virtual group, they have to go through the election process. The election to participate in MIPS as a virtual group has to happen before the performance period and can’t change during the performance period. For the 2018 MIPS performance period, the election period began on Oct. 11, 2017 and ends on Dec. 31, 2017 as described in the 2018 Quality Payment Program final rule. You will find the full two-step process and guidelines located on the QPP Resource page under the 2018 Virtual Group Toolkit link.
5. Why would I join a virtual group?
Solo practitioners or groups with 10 or fewer eligible clinicians (including at least 1 MIPS eligible clinician) may not have enough cases to be reliably measured on their own, but if a solo practitioner or such group forms a virtual group with another solo practitioner or group, together they could increase the performance volume in order to be reliably measured. Additionally, if you’re a solo practitioner and/or have a group with 10 or fewer eligible clinicians and join a virtual group, you’d be able to work together, share resources, and potentially increase performance under MIPS. For a fact sheet and more information, go to the QPP Resource page and click on the 2018 Virtual Group Toolkit link.
Find more QPP resources on the Colorado QPP Coalition webpage, www.cms.org/coqpp.