Practice Management Alert

Question: Our practice has only two providers, and we aren't getting much reimbursement for our Part B patient care. Are there more options for small, rural providers?

North Dakota Subscriber

Answer: The Centers for Medicare and Medicaid Services (CMS) has finalized the option for some practices to join Virtual Groups for the 2018 MACRA Quality Payment Program. Though the Virtual Group option allows clinicians to report together across the four performance categories - Cost, Quality, CPIA, and ACI - CMS still requires the contenders to meet the status thresholds as sole providers or in their small group practices. Many of these clinicians don't even know about MIPS, let alone understand what a Virtual Group is.

Definition: The 2018 MACRA final 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.

Though the language used to describe the Virtual Group option is all about boosting the solo practitioner, some aren't so sure. "Virtual Groups are not a case of CMS championing the little guy," explains Mike Schmidt, director of certification and client success at Eye Care Leaders in Charlotte, North Carolina. "Congress had already required Virtual Groups in MACRA, and CMS had no choice."

Here is a quick overview of the CMS final rule:

• Practices with 10 or fewer providers can now enter into agreements to submit jointly, with all partic­ipants receiving the same MIPS score, regardless of geographic location or clinical specialty.
• 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).

Be wary: Virtual Groups are very new, and there are bound to be kinks. "I don't think anyone, including CMS, has a good sense of how many individuals and small groups will take advantage of the Virtual Group participation option under MIPS," says attorney Benjamin Fee, Esq.  of Dorsey and Whitney LLP in the Des Moines, Iowa office. "While the formal formation requirements are relatively minimal for Virtual Group participation, my sense is that few groups or practitioners who would be eligible are even aware of the option."

One bonus: CMS data suggests that the application process for Virtual Groups will be streamlined. "It [the application] could be used to aggregate all the TINs of a larger practice into a single reporting entity, with the constraint that each TIN is not allowed to exceed 10 providers," mentions Schmidt. "However, the tradeoff between ease of reporting at the practice level versus leveraging the various small practice scoring benefits, the latter is sure to win."

Resource: To find out what QPP, small and underserved practice resources there are in your state, visit https://qpp.cms.gov/about/small-underserved-rural-practices.