Medicare Compliance & Reimbursement

If you’re considering forming a virtual group and registering for the Merit-Based Incentive Payment System (MIPS) for the 2023 performance year, the election period is now open.

Remember: “If your virtual group was approved for the 2022 MIPS performance year and intends to participate in MIPS as a virtual group for the 2023 MIPS performance year, your virtual group must still submit an election to CMS for the 2023 MIPS performance year between October 3, 2022 and December 31, 2022 (11:59 p.m. ET),” reminds the Centers for Medicare & Medicaid Services (CMS) in a Quality Payment Program alert.

The flexibility of the virtual group collaboration allows providers to participate in MIPS who might not be eligible as individual clinicians. With two or more Taxpayer Identification Numbers (TINs), virtual groups can be comprised of the following, according to CMS:

• “Solo practitioners (defined as the only clinician in a practice) who are MIPS eligible; and/or
• “Groups that have 10 or fewer clinicians (at least one clinician within the group must be MIPSeligible). A group is considered to be an entire single TIN.”

Before a virtual group can submit its election application, it must sign a formal written agreement to enter into a virtual group, which lists all TINs involved. CMS offers a sample template in its QPP resource library for creating the contract. A virtual group representative or contact person must also be named prior to the election process.

In addition to the above, “the name and TIN for each practice, and all associated National Provider Identifiers (NPIs) under each TIN” must also be included, the alert advises.

Check out the 2023 Virtual Group Toolkit for additional advice on the election process, CMS says. Submit your election at MIPS_VirtualGroups@cms.hhs.gov.