The Centers for Medicare & Medicaid Services (CMS) has opened an election period from Oct. 11 to Dec. 1 enabling solo and small group practices to qualify as virtual groups for participation in the Merit-based Incentive Payment System (MIPS) program.
In the 2018 Quality Payment Program proposed rule, CMS proposed that solo practitioners or small groups can choose to participate in MIPS as a virtual group for the 2018 performance period.
CMS defines a virtual group as a combination of two or more Taxpayer Identification Numbers (TINs) made up of:
A solo practitioner who is 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 one must be eligi,ble for MIPS) who joins with at least one other solo practitioner or group for a performance period of a year
All solo practitioners and members of small groups planning to form a virtual group must sign a formal written agreement agreeing to participate before an election.
Virtual group elections must include at least the information about each TIN and NPI associated with the virtual group and the virtual group representative’s contact information. Once the election is made, the virtual group representative must contact the Quality Payment Program (QPP) Service Center before the applicable submission period starts with any updates to the election information from the applicable performance period.
Technical assistance is available for the solo practitioner or small group practices QPP technical assistance organizations. Technical assistance resources are listed below:
Small, Underserved, and Rural Support – Help for eligible clinicians in small practices (15 or fewer clinicians), with priority for those in rural locations, Health Professional Shortage Areas (HPSAs) and Medically Underserved Areas (MUAs). You can find the contact information for your local small, underserved and rural support organization by visiting the Small and Rural Practices webpage or by contacting QPPSURS@IMPAQINT.com to get connected.
Quality Innovation Networks- Quality Improvement Organizations (QIN-QIOs) – Help eligible clinicians in larger practices (more than 15 clinicians).
Transforming Clinical Practice Initiative (TCPI) – Helps eligible clinicians in both small and large practices interested in practice transformation and participating in an Alternative Payment Model (APM). Please note that there is a time and data commitment associated with participating in TCPI. Eligible clinicians who are interested in receiving support on virtual groups, or QPP, in general, will need to enroll with a Practice Transformation Network first. For help getting started, contact TCPI.ISCMail@us.ibm.com.
See CMS’ Virtual Groups Toolkit for more information about joining or forming virtual groups.