Medicare Compliance & Reimbursement

With the best intentions to assist smaller practices adjust to the demands of the Quality Payment Program (QPP), MACRA mandated Virtual Groups in its 2017 final rule.

This past June, CMS published its 2018 proposals for MACRA in what the agency is calling the "Quality Payment Program Year 2," vaguely outlining and defining a "virtual" option available for providers who fall under the Merit-Based Incentive Payment System (MIPS).

The 2018 MACRA proposed rule presents the option for smaller practices to join up and submit MIPS measures together as a larger Virtual Group. "Our goal is to make it as easy as possible for Virtual Groups to form no matter where the group members are located or what their medical specialties are," the QPP Year 2 fact sheet says.

Here is a quick overview of what CMS proposes:

• Practices with 10 or fewer providers can now enter into agreements to submit jointly, with all participants receiving the same MIPS score.
• Virtual Groups offer small or solo practices the opportunity to pool costs and other resources, making it easier and less expensive to aggregate their information. Each practice could end up with higher reimbursements and better patient care than if they went at it alone.
• Joining a Virtual Group also lowers certain requirements, including those for your Advancing Care Information (ACI) base score and your Clinical Practice Improvement Activities (CPIA).

Deadline: The window to apply for a Virtual Group for 2018 is now open. Interested providers have until Dec. 1, 2017 to send in an application for the 2018 performance period, noted the MLN Connects from Oct. 19.

Resource: For information about the Virtual Groups' deadline and election toolkit, visit www.cms.gov/Outreach-and-Education/Outreach/FFSProvPartProg/Provider-Partnership-Email-Archive-Items/2017-10-19-eNews.html.