As proposed in the 2018 Quality Payment Program (QPP) proposed rule, solo practitioners and groups can choose to participate in the Merit-Based Incentive Payment System (MIPS) as a virtual group for the 2018 performance period. To form a virtual group for 2018, solo practitioners and groups would need to engage in an election process. For the 2018 MIPS performance period, the election period for virtual groups to make an election is from October 11, 2017 to Friday, December 1, 2017.
The Centers for Medicare and Medicaid Services (CMS) has proposed a virtual group to be a combination of two or more Taxpayer Identification Numbers (TINs) made up of:
- A solo practitioner who’s eligible to participate in MIPS and bills under a TIN with no other National Provider Identifiers (NPIs) billing under the TIN, OR
- 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.
To form a virtual group, CMS has proposed a two-stage virtual group election process:
- Stage 1 (optional): Solo practitioners and groups with 10 or fewer eligible clinicians may contact their designated Technical Assistance representative or the QPP Service Center to determine if they are eligible to join or form a virtual group.
- Stage 2: For groups that choose not to participate in Stage 1 of the election process, CMS will determine if they are eligible in Stage 2. During Stage 2, the virtual group must name an official representative who will submit their election to CMS via email to MIPS_VirtualGroups@cms.hhs.gov by Friday, December 1, 2017.
- A written formal agreement between each of the virtual group members; and
- Information about the TIN and NPI associated with the virtual group representative’s contact information.
For more information about joining or forming virtual groups, see the Virtual Groups Toolkit.
Need Help with the Election Process?
Contact the QPP at QPP@cms.hhs.gov or call 866.288.8292 (TTY: 877.715.6222). You can also contact your local support organization for support.