Introduction to MIPS 2023 Reporting and Virtual Groups

The snowy winter season has arrived, marking a pivotal time in the MIPS 2023 reporting process. Clinicians engaged in MIPS 2023 have successfully completed segment 2 of their reporting. As we approach the final eligibility determination, the submission window is set to open soon. Additionally, virtual group elections for MIPS 2024 will commence on October 2, 2023. Clinicians, whether solo practitioners or part of a group, should act promptly to participate in MIPS 2024.

In this blog, we will explore three key advantages of virtual group reporting. Before diving into those benefits, let’s take a moment to introduce virtual groups for our readers.

Understanding Virtual Group Reporting

What Are Virtual Groups?

The Quality Payment Program (QPP) MIPS framework permits eligible clinicians to choose from four reporting options:

– Group
– Virtual group
– Individual group
– APM entity

Clinicians have the flexibility to select how they wish to participate in MIPS 2024. Each participation type comes with unique advantages, including potential special status within MIPS. For this discussion, we will focus on the formation of virtual groups.

How Virtual Groups Operate

A virtual group consists of two or more Tax Identification Numbers (TINs) that collaborate with eligible solo practitioners or groups. This structure allows:

– One or more eligible solo practitioners
– One or more groups (comprising 10 or fewer clinicians, with at least one MIPS-eligible clinician)
– A combination of both solo practitioners and groups

As they collaborate, they receive a combined MIPS final score. It is essential for solo practitioners or groups to elect their virtual groups and select their official representatives while keeping the Centers for Medicare & Medicaid Services (CMS) updated on any changes. Throughout the performance year, a solo practitioner or group can participate in only one virtual group.

Benefits of Participating in a Virtual Group

Participating in a virtual group for MIPS 2024 offers several distinct advantages, although it is important to note that this option is exclusively for MIPS reporting. Virtual groups cannot report through the APM Performance Pathway (APP) or MIPS Value Pathways (MVPs) for MIPS 2024. Thus, decision-making regarding participation is crucial.

1. Expansion of MIPS Performance Volume

The old adage “unity is strength” aptly describes the benefits of virtual groups. MIPS-eligible participants may encounter difficulties in reporting cases. However, by combining their TINs for MIPS 2024, they can significantly increase their MIPS performance volume.

2. Enhanced Collaboration and Resource Sharing

Another key benefit of participating in a virtual group is the opportunity for resource sharing. Members can collaborate effectively, thereby enhancing their overall performance potential in MIPS.

3. Flexibility in Structure

Virtual groups provide considerable flexibility in determining their structure. Participants are not limited by factors such as location or specialty, allowing them to shape their virtual group according to their preferences. There is also no cap on the size of the group, so whether you are a solo practitioner or part of a small group with at least one MIPS-eligible clinician, you have the freedom to design your virtual group as you wish.

Eligibility Criteria for Virtual Group Participation in MIPS 2024

To participate in a virtual group, clinicians must meet specific eligibility criteria.

Requirements for Solo Practitioners

To qualify as an eligible solo practitioner, one must:

– Belong to a MIPS-eligible clinician type
– Exceed at least one low-volume threshold element
– Have completed Medicare enrollment as a clinician before the start of FY 2024
– Not be a Qualifying Participant (QP) or partial QP opting out of MIPS

Requirements for Groups

For a group to be eligible, the following conditions must be met:

– The NPIs under the Tax Identification Number (TIN) collectively exceed at least one low-volume threshold element.
– The group consists of 10 or fewer clinicians, including at least one MIPS-eligible clinician who has reassigned their billing rights to the TIN.

It is important to note that a virtual group may include both MIPS-eligible and non-eligible clinicians. Consequently, the total number of NPIs billing under the TIN will determine the group size. If a group decides to join a virtual group, all clinicians within that group will automatically participate.

Additionally, virtual groups can include clinicians participating in Advanced Alternative Payment Models (APMs). Clinicians in advanced APMs may achieve Qualifying APM Participant (QP) status, exempting them from MIPS.

Conclusion

As MIPS 2024 approaches, eligible clinicians face new challenges. Although there is still time before the start of PY 2024, the preparation phase has begun. Alongside ongoing reporting for FY 2023, clinicians must also prepare for the upcoming year. The first step in this preparation is selecting a participation type. Solo practitioners and groups eager to assign their TINs to virtual groups should act now, as the virtual group election period has started. We hope this blog assists you in understanding the benefits of joining a virtual group for the coming year.