MIPS: Last Day to Elect to Participate in a Virtual Group for the 2018 MIPS Performance Period
Under the Medicare Access and CHIP Reauthorization Act (MACRA), the Centers for Medicare & Medicaid Services (CMS) designed a new Quality Payment Program that has two payment pathways: the Merit-Based Incentive Payment System (MIPS) and advanced alternative payment models (APMs). The CMS Quality Payment Program began on Jan. 1, 2017. Physicians participating in MIPS this year participate individually or as a group. However, for the 2018 MIPS performance period, CMS is introducing a third participation option. Next year, physicians may participate in MIPS individually, as a group, or in a "virtual group." This option is voluntary and provides solo practitioners and small group practices the ability to band together to form a virtual group for the purposes of MIPS participation. A virtual group is a combination of TINs. CMS defines a virtual group as a combination of two or more TINs assigned to one or more solo practitioners who are also MIPS eligible clinicians or to one or more groups consisting of 10 or fewer eligible clinicians (including at least 1 MIPS eligible clinician), or both, that elect to form a virtual group for a performance period for a year. A group is considered to be an entire single TIN that elects to participate in MIPS as part of a virtual group.
Medicare policies and criteria surrounding virtual groups were published by CMS in the 2018 Quality Payment Program final rule in early November. If you plan to participate in a virtual group, you will need to complete an election process. The virtual group must name an official representative who will submit the group's election to CMS via email to by Dec. 31, 2017.
For guidance from CMS, access and download the 2018 Virtual Groups Toolkit by clicking on the CMS link above. For questions, contact the CMS Quality Payment Program Service Center at (866) 288-8292 or email at For technical assistance, contact the TMF Health Quality Institute at (844) 317-7609 or, or submit an online help request at .