There’s no time to waste for physicians or group practices that want to form a virtual group for 2018 as a way to participate in the Merit-based Incentive Payment System (MIPS).
The Centers for Medicare & Medicaid Services has set Dec. 1 as the deadline by which solo and small group practices must tell the agency they want to elect to participate in a virtual group—a concept introduced in the proposed rule outlining changes to MACRA for 2018.
Virtual groups is a new reporting option for practices set forth in the proposed rule, which CMS must finalize by Nov. 1. Virtual groups allow solo physicians and small practices to band together to report Medicare performance measures and mitigate risk.
Solo practitioners or group practices with 10 or fewer clinicians who are eligible to participate in MIPS have the option to form a virtual group. To do so, they need to execute a formal and contractual written agreement, according to the CMS website. Each virtual group member needs to sign that agreement, which would apply to at least one performance period.
The program is likely to get off to a small start as CMS predicts that just 16 virtual groups made up of perhaps 765 physicians nationwide will form for 2018 given the tight timeframe.
CMS has created a virtual groups toolkit which physicians can download to learn more about the option. The toolkit contains an agreement checklist, a template and details about the election process.
CMS said it intends to provide technical assistance to help with the election process and plans to provide additional information to support doctors and practices who want to form a virtual group once it publishes the final rule in the next two weeks. But that leaves a short window to make an election by Dec. 1, before the 2018 performance period begins.
A major challenge in forming virtual groups is for physicians and practices to identify reliable clinicians or group practices that may make good partners. Physicians are advised to choose carefully and make sure partners are focused on quality care. Under the proposed rule, a performance period is one year, locking physicians and small practices into a situation where they must report quality data jointly with their partners and receive a group performance score.
CMS is offering an optional process for those who want to determine their eligibility to participate as a virtual group before they make any formal written agreements or send in a formal election registration. Clinicians can contact their local Quality Payment Program technical assistance organization (PDF) to help determine if they are eligible to join or form a virtual group, with details provided in the toolkit.
Reasons for joining together
For small practices, it's difficult to get significant statistics on many of the performance measures under MIPS and those who join a virtual group are likely to get much more reliable results.
The American Academy of Family Physicians is one organization that has welcomed the creation of virtual groups. They offer a better chance for success under MIPS for small practices that want to remain independent by allowing them to band together for reporting purposes, Amy Mullins, M.D., medical director of quality improvement, told AAFP News.
"The larger the sample on quality—meaning the larger the group—the better the quality metrics potentially could be," Mullins told the publication. By pooling their risk, a practice’s score won’t be affected by, for instance, a single patient with a bad outcome, she said.