An important deadline is approaching for groups and physicians participating in MIPS in 2018. December 31 marks the last day for clinicians to notify CMS that they are electing to participate in a Virtual Group for MIPS 2018.
If you aren’t familiar with Virtual Groups, you aren’t alone. Virtual Groups are a brand new option for MIPS participants in 2018 (Just one of several changes that CMS is implementing – check the details in this blog post). These Virtual Groups allow clinicians from around the country to team up with each other to help satisfy MIPS requirements.
To help groups and clinicians prepare to participate in a Virtual Group in 2018, we have compiled some FAQ about the program from the final rule published by CMS.
A Virtual Group is defined as a combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of 10 or fewer eligible clinicians that elect to form a virtual group for a performance period for a year. There is currently no limit on the number of TINs that can participate in a virtual group (i.e. one provider might have multiple TINs from multiple practice locations and can form a virtual group as a solo practitioner). Virtual Groups have the flexibility to work with other groups or types of practices from any location. This could open the door for more clinicians to join the program and work with their peers, regardless of their geographical proximity.
Individual MIPS eligible clinicians or groups electing to be in a Virtual Group must make their election prior to the start of the applicable performance period and cannot change their election during the performance period. The deadline for such an election was recently extended to December 31, 2017.
No. Each eligible clinician or group may only elect to be in one Virtual Group at a time. In the case of a group, the election applies to all MIPS eligible clinicians (NPIs) in the group.
Each MIPS eligible clinician who is part of a Virtual Group will be identified by a unique Virtual Group participant identifier. This unique identifier is composed of a combination of the following identifiers: 1) Virtual Group identifier (established by CMS) 2) TIN number and 3) NPI number.
Virtual Groups have the same reporting requirements as other MIPS participants. There are still special exceptions for non-patient facing practices, small practices, rural practices, and practices with HSPA status. For the most part, policies that apply to regular group reporting also apply to virtual group reporting.
1. Determining eligibility – Contact TA representative
2. Executing formal written agreements – TINs comprising a virtual group must establish a written formal agreement between each member of a virtual group prior to election
3. Submitting formal election registration – On behalf of the virtual group, the official designated virtual group representative must submit an election by December 31, 2017. – Such an election will occur via email to the Quality Payment Program Service Center using the following email address: MIPS_VirtualGroups@cms.hhs.gov – Submission must include, at a minimum, information pertaining to each TIN and NPI associated with the virtual group and contact information for the virtual group representative. – Each TIN associated w/the virtual group – Each NPI associated with the virtual group – Name of the virtual group representative – Affiliation of the virtual group representative to the virtual group – Contact information for the virtual group representative – Confirmation through acknowledgement that a formal written agreement has been established between each member of the virtual group (solo practitioner or group) prior to election and each eligible clinician is aware of participating in a MIPS virtual group for an applicable performance period. – Each party must retain a copy of the virtual groups written agreement and is subject to the MIPS data validation and audit process.
4. Allocating resources for virtual group implementation and related activities
If approved to participate in a virtual group, CMS will contact your group representative via email to notify them of their status and issue a virtual group identifier for performance.
CMS released a Virtual Group Toolkit to get started with the election process. It can be downloaded here.
Yes! SurveyVitals is a CMS-certified CAHPS vendor ready to administer CAHPS for MIPS. Additionally, SurveyVitals can help organizations meet 6 different Improvement Activities to satisfy MIPS requirements. And if you are an anesthesiologist, we can also help you meet a measure in the Quality Category via QCDR reporting.
Schedule a demo today to learn more about how SurveyVitals can help with MIPS in 2018.macra, MIPS, reporting, virtual groups
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