The second year of the Merit-based Incentive Payment System (MIPS) has proposed new option for participation, with clinicians able to join together in “virtual groups” to report on MIPS performance measures.
Its inclusion in the proposed 2018 rule on the Medicare Access and CHIP Reauthorization Act (MACRA) payment tracks has been tentatively praised, but the actual process of forming these virtual groups provide some potential pitfalls for providers. In a presentation at the 2017 Medical Group Management Association (MGMA) conference in Anaheim, Calif., MGMA senior consultant Pam Ballou-Nelson, RN, MSPH, PhD, offered some tips on how small practices and solo practitioners can navigate this new option.
1. What makes a virtual group
Tax identification numbers (TINs) make up the basis of a virtual group. The group can consist of either two separate TINs associated with a solo practitioner TIN and a National Provider Identifier (NPI), a group of 10 or fewer MIPS-eligible clinicians and a solo practitioner or just a group of 10 or fewer MIPS-eligible clinicians.
Ballou-Nelson emphasized that all the NPIs under a TIN have to agree to participate in the virtual group. The groups don’t have to be connected geographically or by specialty. The agreement creating the group must be signed by each clinician, not by any other entity, such as an independent practice association. The group will then report on all MIPS measures as if they were under one TIN.
2. Once you’re in, you’re in, and the deadline is fast approaching
The virtual groups must elect this participation option before Dec. 1, according to the timeline laid out in the proposed rule. Several stakeholders, including the American College of Cardiology, have asked CMS to push up the election deadline until Jan. 1, 2018, to allow these virtual groups extra time to form.
What isn’t likely to change, according to Ballou-Nelson, is a clinicians’ level of participation once a group has been formed and the 2018 performance period has begun.
“If you enter into this and we put into your agreement between now and Dec. 1 and you start your virtual group in 2018, then that’s it, you have to stay within that virtual group," she said.
3. The low-volume thresholds still apply
An important caveat to the virtual group option is all the clinicians would have to already be meeting the requirements to participate in the program. Under the proposed rule, clinicians are exempt from MIPS participation if they bill less than $90,000 in Medicare Part B charges and treat fewer than 200 Medicare patients. If a clinician doesn’t meet that threshold, they can’t join a virtual group.
“It was first thought would help those practices that are in the low threshold categories join with another practice within the virtual group so they would have the upper level threshold requirements,” Ballou-Nelson said. “That is not the case.”
4. Participation is expected to be low
Some 65 percent of clinicians were already exempted from MIPS in 2017 before the low-volume thresholds would be raised. This would leave an even smaller pool of clinicians potentially interested in the virtual group option.
“The goal of CMS is about 20 groups for 2018,” Ballou-Nelson said. “It’s a kind of a testing period for them.”
5. Virtual groups could serve as precursor to forming an ACO
In the long term, those independent clinicians working together as virtual groups in 2018 could expand their partnership in 2019 and beyond, perhaps serving as a prelude to forming an accountable care organization (ACO), which could open possibilities to participate in MACRA’s Advanced Alternative Payment Models track.
“It gives them an opportunity to test this ability to test this ability to work together and collaborate over some quality measures, improvement activity measures and how you’re going to streamline data collection and technology efforts,” Ballou-Nelson said.