In the first performance year of the Quality Payment Program (QPP), small practices carried the heaviest load as they found it difficult to get ready and perform well under the MIPS payment track. Simply put, they didn’t have as much data to collect as did the larger practices who saw many more Medicare Beneficiaries. With patient compliance playing a key role in the data they were reporting, solo practitioners and small rural practices found it somewhat overwhelming to find the right measures that they could perform well under. Additionally, the concern of having to implement improvement activities and find affordable certified electronic health record technology (CEHRT) left many of them frustrated and wondering if they could continue private practice at all.
Thankfully, the Centers for Medicare and Medicaid Services (CMS) heard the voices of clinicians who quickly offered negative feedback, citing the QPP encumbered their practice to such a degree they weren’t sure of their futures. CMS took note of the struggle and sought out a plausible answer that would allow small practices to not only participate in the QPP but to perform well.
The answer CMS has brought to the 2018 performance year is Virtual Groups. In essence, practices with 10 or less eligible clinicians can come together virtually to report as a group for the MIPS payment track. The minimum requirement is that one solo practitioner joins one other solo practitioner to report together as a group. However, there are some qualifications that apply when making this consideration.
If you are a practitioner that is seeking to join a virtual group you must be considered a MIPS eligible clinician who is not exempt from MIPS based on one of these exclusions:
- In 2017, you cannot have exceeded the low-volume threshold through either too many payments or too many Medicare Beneficiaries;
- You must have been enrolled and treating Medicare Beneficiaries for more than one full year in order for CMS to have enough data;
- You cannot be a Qualified APM Participant, meaning you saw more than 20% of your Medicare Beneficiaries through an Advanced APM or received more than 25% of your payments through an Advanced APM during 2017.
- You cannot be a “Partially” Qualified APM Participant, meaning you saw more than 10% of your Medicare Beneficiaries through an Advanced APM or received more than 20% of your payments through an Advanced APM during 2017.
It’s important to note that if you are leaning towards joining a Virtual Group for the 2018 performance year, you will need to make that decision prior to the beginning of that year. Additionally, if a group practice with 10 or fewer eligible clinicians chooses to join a virtual group, all clinicians under that TIN would be considered part of that group. Once again, this is part of the proposed rule for 2018. More information will be forthcoming when the final rule is released early this fall.