The benefits and challenges of joining CMS' Virtual Group option for healthcare providers to report their Quality Payment Program (QPP) measures from 2018.
CMS created a Virtual Group option for healthcare providers to report their Quality Payment Program (QPP) measures from 2018. The group is defined as a combination of 2 or more Taxpayer Identification Numbers (TINs) assigned to 1 or more solo practitioners, or to 1 or more groups consisting of 10 or fewer clinicians (including at least 1 clinician eligible for the Merit-based Incentive Payment [MIPS] program), or both, that elect to form a virtual group for a performance period for a year.
This new “group reporting” will allow multiple/different TINs and CMS will assign a new, unique identifier. For example, 5 TINs with 9 clinicians each could join and form a virtual group of 45 total clinicians.
While the program is entirely voluntary, practices must be a solo practitioner or in a group that has 10 or fewer clinicians. There are no limits as to how many solo practitioners or groups can join, but in the case of groups, all clinicians in that specific TIN are included in the reporting. Therefore, practices cannot pick and choose which physicians are represented in the reporting. This is an important consideration as one physician’s performance could impact reporting for the rest of the group. There are also no restrictions based on location or specialty.
Virtual groups have been formed for the 2018 reporting year, but CMS will open the application process again for the 2019 reporting year, typically around mid-September. There are several steps to forming a virtual group, including an approval process with CMS, designating a Group Representative and executing formal written agreements between all parties. CMS has guidelines available about what must be included in the written agreements for virtual groups in their toolkit.
The benefits of joining a virtual group:
The challenges with joining a virtual group:
CMS created options for joining virtual groups—by either creating one on your own, or requesting eligibility to join a virtual group through CMS. If a practice or clinician decides to join or create a virtual group, they must contact their CMS Technical Assistance Representative to determine eligibility, prior to any formal agreements being drafted.
In any event, eligible clinicians need to decide the best option for themselves. CMS has offered a toolkit which outlines the process for joining or creating a virtual group, along with resources to get more information. Additionally, it is recommended that if your practice requires any assistance or advice as to whether to join a virtual group, a seasoned consulting professional with a robust level of expertise should be sought.