There are many ways of participation in MIPS reporting for eligible clinicians. Traditional Merit-based Incentive Payment System allows the same four ways for PY 2023 as well:
- An individual
- A group
- A virtual group
- An Alternative Payment Model (APM) Entity
The process of MIPS reporting and evaluation varies a little for all these participant types. However, QPP MIPS implements all types as per its traditional framework. We have vast information on participation as an individual and a group in traditional MIPS. But participants thinking of reporting as a virtual group or an APM entity might face a little hassle before knowing the actual process. Their unawareness and lack of information about the whole process often puts them in bad situations.
Here in this blog, we will be identifying what a virtual group is. Also, we will be listing significant events that will happen during the virtual group elections in PY 2023.
What is a Virtual Group?
A virtual group is one of the participation types for MIPS reporting that are eligible for reporting via the MIPS program only. This means they can never report via other QPP pathways for PY 2023. For example, a virtual group has a restriction on participation in APM Performance Pathway (APP) and MIPS Value Pathways (MVPs).
In general, a virtual group comprises two or more TINs (Taxpayer Identification Numbers) that are assigned to:
- One or more MIPS-eligible solo practitioners /
- One or more groups of 10 or few clinicians, having a minimum 1 MIPS eligible clinician in the group /
- A MIPS-eligible solo practitioner and 10 or fewer clinicians group with at least 1 MIPS EC – both of them elect and form a virtual group for MIPS reporting.
Who are Virtual Group Participants?
As we know both solo practitioners and a group with 10 or fewer clinicians can be virtual group participants. Anyhow, there is a set of requirements for them to fulfill.
- Virtual Group Participation Criteria for Solo Practitioners
- Must be MIPS eligible clinician
- Have an enrollment in Medicare before the commencement of PY 2023
- Able to score above low-volume threshold in at least one element
- Not be a Qualifying APM Participant (QP)
- Must not have partial status (selects not being a part of MIPS)
- Virtual Group Participation Criteria for Clinician’s Group
The clinician group size for virtual group election depends on total NP1s in total that bill under a TIN. This group can include both types of clinicians; MIPS eligible or not eligible. Usually, the group is of 10 or fewer clinicians with their billing rights registered to that TIN.
Every clinician in the group is a valuable part of that group throughout the virtual group election. They must get a score above the low-volume threshold in at least one element at the group level.
The group can include participants of Advanced APMs as their group members. However, if they get QP status in Advanced APMs, they will automatically be excluded from the MIPS program.
What Happens in Virtual Group Elections?
The Merit-based Incentive Payment System mandates the formation of virtual groups before the start of PY 2023. Therefore, the virtual group election phase marks the member’s selection period under a virtual group participation type.
The elections for PY 2023 virtual group selection began on Monday, October 3, 2022. And, it is about to finish on December 31, 2022, following a 2-step process. Once they pick their virtual group, the group has a revision choice to retract their virtual group election. They can do so by 11:59 p.m. ET on December 31, 2022. After this, they will enter the MIPS 2023 performance year.
A solo practitioner or a clinician’s group in a virtual group signs written documentation as an agreement. The validity of this agreement is for one performance year at least. The virtual group also makes an official representative who can report the group’s composition changes during the performance year. Group composition changes don’t affect the group elections at all. The virtual group’s official representative actively informs the Quality Payment Program about all such changes.
Key Event of PY 2023 Virtual Groups
Here, we have listed all the major events that you will face during your elections in the formation of virtual groups in PY 2023.
- October 3, 2022, Virtual Group Election Period Begins
It’s time for virtual group election submission. Check if you fulfill the participation requirement for MIPS reporting as a virtual grouping. Sign in to the QPP web portal for this purpose. For other queries, you may connect to the Quality Payment Program Service Center.
- December 31, 2022, Virtual Group Election Period Finishes
(11:59 p.m. ET)
Revise or retract your virtual group till this date. After this, you are left with no alteration option to your election.
- January 1, 2023, MIPS Performance Year Commence
Time to collect MIPS reporting data for your participation type (VG) as MIPS 2023 performance period has begun.
- April 3, 2023 | CAHPS for MIPS Survey; Registration Open
It is an optional quality measure. If you want to report your data to CMS by this option, then enter the registration phase.
- June 30, 2023, CAHPS for MIPS Survey; Registration Close
The CAHPS for MIPS 2023 registration period will end at this date.
- December 31, 2023, MIPS Performance Year Ends
(11:59 p.m. ET)
By this date, the performance year 2023 will come to an end. Make sure you are in connectivity with your virtual group throughout the year.
That’s all about virtual groups. This option, which was first established as the MIPS participation type in 2018, relieved the MIPS reporting burden of solo practitioners and groups. If you are thinking of being a part of a virtual group for PY 2023, then select your virtual group via elections now.