Health Care E-lert -- As a Physician How Do I Form a Virtual Group To Qualify for MIPS?

Starting with calendar year 2018 the Centers for Medicare and Medicaid Services(CMS) created a virtual group option to encourage broader Merit Incentive Payment System (MIPS) participation for solo practitioners and groups with 10 or fewer eligible clinicians.

Physicians are increasingly understanding the importance of figuring out how to participate in MIPS to avoid a negative payment adjustment under Medicare B payments in future years. You can go on the CMS Quality Payment Program site and look yourself up by your NPI to see if you are a MIPS eligible physician.

The virtual group is defined as:

  1. a combination of two or more TINs assigned to one or more solo practitioners who are also MIPS eligible clinicians; or
  2. one or more groups consisting of 10 or fewer eligible clinicians (including at least 1 MIPS eligible clinician), or both, that elect to form a virtual group for a performance period for a year.

Groups are identified by their TIN and individual eligible clinicians are identified by their TIN/NPI combination.

The election period to form a virtual group for 2019 is fast-approaching. A defined election process must be followed and submitted via e-mail to CMS. This period to make this election starts in October, and ends on December 31, 2018.

If you're ready to get started, a toolkit is now available (developed by CMS) which Physicians can download which includes (i) an overview of the virtual group - what it is and who can participate; (ii) an explanation of the process to form a virtual group for calendar year 2019; (iii) a template to develop a virtual group agreement; (iv) a sample e-mail to send for virtual group election submission.

Rupa S. Lloyd 
GrayRobinson, P.A.
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