Learn More About Forming a Virtual Group to Participate in MIPS in 2018

November 06, 2017

Apply Now Until December 31 to Form a Virtual Group for MIPS in 2018

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 must follow an election process, and submit their election to CMS by December 31, 2017.

What is a Virtual Group?
As outlined in the Quality Payment Year 2 Final Rule, a virtual group is a combination of two or more Taxpayer Identification Numbers (TINs) made up of one or more solo practitioners or one or more groups consisting of 10 or clinicians (including at least 1 MIPS eligible clinician), or both, that elect to form a virtual group for a performance period for a year. To be eligible to join a virtual group, you must be a:

  • Solo practitioner who exceeds the low-volume threshold; and who is not a newly Medicare-enrolled eligible clinician, a Qualifying APM Participant (QP), or a Partial QP choosing not to participate in MIPS.
  • Group that exceeds the low-volume threshold at the group level (i.e., the NPIs within the TIN collectively exceed the low-volume threshold) and has 10 or fewer clinicians (including at least 1 MIPS eligible clinician).

How Do I Form a Virtual Group?
To form a virtual group, there is a two-stage virtual group election process:

  • Stage 1 (optional): If you’re a solo practitioner or a group with 10 or fewer eligible clinicians, you can choose to contact your Quality Payment Program Technical Assistance representative. Your representative can help you figure out if you're eligible to join or form a virtual group before you: 
    1. Make any formal written agreements. 
    2. Send in your formal election registration. 
    3. Budget your resources for your virtual group.

For groups that don’t participate in stage 1 of the election process and don’t ask for an eligibility determination, CMS will see if they’re eligible to be in a virtual group during stage 2 of the election process.

  • Stage 2 (required): As part of the stage 2 election process, a virtual group must have a formal written agreement between each solo practitioner and group that composes the virtual group prior to submitting an election to CMS. Each virtual group has to name an official representative who is responsible for submitting the virtual group's election via e-mail to MIPS_VirtualGroups@cms.hhs.gov by December 31, 2017.

If all the criteria for forming a virtual group are met, CMS will contact the virtual group’s representative and provide the virtual group with a performance identifier.

Learn More about Virtual Groups
For more information about participating in MIPS as part of a virtual group, the election process, and formal agreements, please see the Virtual Groups Toolkit. The toolkit contains:
- Virtual Group Participation Overview Fact Sheet

- Virtual Groups Election Process Fact Sheet
- Virtual Groups Agreement Checklist
- Virtual Groups Sample Agreement Template

Need Help with the Election Process?
Contact the QPP Resource Center: www.qppresourcecenter.comqppinfo@altarum.org or 1-844-QPP-4YOU

Or contact the CMS QPP Service Center: QPP@cms.hhs.gov or 1-866-288-8292 (TTY: 1-877-715-6222).