Small physician groups and solo practitioners take heart: CMS wants you to be successful in the Merit-based Incentive Payment System (MIPS) without having to merge or be acquired.
CMS has proposed to ease the burden of implementation for independent and small group providers by allowing them to band together virtually. These virtual groups are just one of the ways a proposed rule announced in June would reduce the regulatory burden of participating in MIPS and Advanced APMs.
Here’s the rub: Given that elections are due in December, providers will have to act fast to take advantage of this option for the 2018 performance year. If you wait until the CMS rule is finalized (around November 1), then you will have about a month to jump through all the hoops of identifying your group members, determining the group’s eligibility, drawing up the required agreements and choosing quality metrics that make sense for all participating providers.
But CMS is not unreasonable. During focus groups and listening sessions, the agency heard that practitioners would need anywhere from three months to a year or more to form a virtual group, prepare health IT systems and train staff on new processes. In response, CMS is planning to open up early election beginning around mid-September. Watch for additional details about this option in upcoming CMS guidance.
Next week, we’ll address factors to consider in deciding whether to form a virtual group. In the meantime, below are just a few of the details you will need to know to make this determination.
What is a “Virtual Group”?
- A solo practitioner, or
- A group with 10 or fewer MIPS eligible clinicians (ECs).
For now, CMS is refraining from applying any additional restrictions on the makeup of the group. For example, the agency decided not to limit the number of providers or the types of providers in the group—although it reserves the right to restrict these things in the future.
The takeaway here is that providers have a great deal of flexibility right now to form the kinds of groups that make the most sense for them. CMS might (and probably will) restrict this flexibility in the future, which is a compelling reason to jump on the bandwagon early.
How Will Virtual Groups be Scored?
Virtual groups will have their performance assessed at the group level, and the performance score for that group will be applied to each individual MIPS eligible clinician.
One of the areas of debate is whether the groups will be assessed on all four QPP performance categories (cost, quality, improvement, advancing care information). Under previous rules, virtual groups were to be assessed as a group only for the quality and cost performance categories. However, CMS argues that assessing the whole group for all performance categories eliminates unnecessary burden for virtual group members who would otherwise have to report some measures as a group and others individually.
What Technical Support Will Virtual Groups Receive?
Knowing that solo physicians and small groups have limited technical and staff resources, CMS has offered virtual groups access to technical assistance from the QPP Service Center for the first two years (2018 and 2019).
Deciding whether a virtual group is right for you and your practice is a strategic decision that requires careful consideration of the risks and benefits. Next week, we’ll take a closer look at some of those considerations. Remember that CMS is taking comments on the proposed rule at https://www.regulations.gov/ through August 21. For more information, contact the agency at QPP@cms.hhs.gov.
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