Physicians participating in Medicare's Merit-Based Incentive Payment System (MIPS) have the option of reporting data for 2018 as an individual eligible clinician (EC), as part of a group practice that bills Medicare using the same Taxpayer Identification number (TIN), or as part of a virtual group. The latter option is available to a group with 10 or fewer ECs or an EC in solo practice who might want to join forces with at least one or more similarly sized practices for the purpose of reporting MIPS data for a performance year. A solo practitioner participating under two TINs may even form a virtual group across both practices.
The virtual group election period for the 2018 reporting period began in October and will close on December 31, 2017; virtual group reporting is not an option for the 2017 reporting period. Unless otherwise indicated in the Quality Payment Program (QPP) Final Rule for 2018, virtual groups will follow the same rules as other group practices participating in MIPS. The following are some key details relative to the formation of a virtual group.
Composition
A virtual group must contain TINs of 10 or fewer eligible clinicians. TIN size is determined by including in the count those ECs who would otherwise be exempt from MIPS based on low volume, low Medicare dollars, or their first year of Medicare participation.
Election process
The election to participate in MIPS as a virtual group must occur prior to the start of the applicable performance period and it cannot be changed during the performance period. The two-stage virtual group election process is as follows:
- Stage 1 (optional): Determine if solo practitioners and groups are eligible to participate in a virtual group.
- Stage 2 (required): Virtual group applicants submit the necessary information, including a virtual group agreement, to gain approval to form a virtual group for the upcoming performance period. The approval needs to be renewed each year.
Virtual group agreement
A formal, legal written agreement must be established among the solo practitioners and groups that make up a virtual group. It has to include a list of the eligible clinicians who bill under the TINs who will be members of the virtual group. The participation requirements and expectations are to be clearly articulated, understood, and agreed upon. The virtual group agreement must be executed on behalf of each TIN by an individual who is authorized to legally bind the party.
Participant identifier
Each MIPS-eligible EC who is part of a virtual group will be identified by a unique virtual group participant identifier that is made up of a combination of three identifiers:
- A virtual group identifier established by Medicare
- The EC's TIN
- The EC's National Provider Identifier (NPI)
Reporting
Virtual group reporting poses new requirements and challenges, as clinicians will have their performance assessed at the virtual group level across all applicable MIPS performance categories. Here are some reporting considerations:
- The data will be aggregated for each NPI under each TIN participating in a virtual group. Such aggregation across multiple TINs and associated health IT systems may be complex and logistically difficult because each TIN may use IT systems with different ways of collecting and storing data.
- Third-party vendors such as qualified data registries, qualified clinical data registries, and electronic health record (EHR) providers will be required to provide methods to collect and aggregate MIPS data from various disparate systems.
- While all of the eligible clinicians in a TIN reporting within the virtual group are required to participate and have their performance scores included in the virtual group score, only "MIPS-eligible" clinicians will receive a MIPS payment adjustment based on the virtual group's score. A MIPS-eligible clinician is an EC who is not exempt from MIPS based on the exclusion criteria described above.
- MIPS-eligible clinicians who participate in both a virtual group and an alternative payment model (APM) under their TIN will be assessed on their MIPS performance as part of the virtual group and under the APM scoring as part of an APM Entity group, but they will receive their payment adjustment based only on the APM Entity score.
Virtual group reporting pros and cons
The virtual group concept might initially sound attractive to a small practice. Advantages may include shared responsibility and shared risk, as well as the availability of resources to support and positively affect performance in the MIPS program that might not otherwise be available to smaller groups or individuals. However, putting the plan into operation could be a bigger challenge than expected, and once the election is made, it will be irrevocable for one performance period.
Therefore, eligible clinicians who are contemplating the formation of a virtual group should consider these pros and cons:
- It could be difficult to aggregate data across disparate systems for unified reporting of MIPS measures and activities.
- Control of the virtual group's success will be in the hands of an administrator who may not be part of your own practice.
- There may be logistical challenges in trying to manage groups that are working in different systems, geographies, and reporting structures in order to gain compliance. To be successful, there is a need for clear oversight, trust, and commitment among the virtual group's members.
- Your practice will suffer if another virtual group member doesn't optimize participation. This would bring down the overall virtual group score that is then attributed to every member of the virtual group.
- Virtual groups are assessed across all four MIPS performance categories that apply to any of its members. Therefore, if a radiology practice that is exempt from the advancing care information (ACI) performance category because it is hospital-based and/or nonpatient-facing joins with a practice that is not exempt from ACI, the practice will also absorb the ACI score from the other practice as part of the overall MIPS score across the virtual group. This could be positive or negative depending on the ACI score. However, it means that each member has even less control over this portion of the MIPS score that will affect its future payments.
- Existing contractual obligations with other provider organizations and groups might affect the formation of a virtual group.
- Providers may be unaware of their obligation to participate in the virtual group, especially if it has to support many TINs. This is similar to what the U.S. Centers for Medicare and Medicaid Services (CMS) has found regarding provider participation in APMs. The addition or departure of ECs within a TIN could prove difficult to manage relative to their obligation to participate in the virtual group, which could affect the TIN's eligibility to continue in the virtual group in subsequent performance years.
- If a solo clinician or group practice is not eligible to participate in MIPS, then they are also not eligible to participate in a virtual group.
Conclusion
Radiology practices that are interested in forming a virtual group should download the Virtual Group Toolkit from the CMS Resource Library and follow the directions for making the election. There is a very short window of opportunity to form a virtual group and make the election for the 2018 performance year.
Rebecca Farrington serves as chief revenue officer for Healthcare Administrative Partners. She has more than 20 years of experience in healthcare sales and management roles, focusing on hospital-based and physician revenue cycle management.
The comments and observations expressed herein are those of the author and do not necessarily reflect the opinions of AuntMinnie.com.
