Should radiologists participate in MIPS as part of a virtual group?

When the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) passed, CMS established two ways for physicians to be rewarded for providing high-value care through a Quality Payment Program (QPP): the Merit-Based Incentive Payment System (MIPS) and advanced alternative payment models. Since the beginning, physicians have been able to participate in MIPS as an individual or as a group—but now they can also participate as a virtual group.

A team of researchers, led by lead author Lauren Parks Golding, MD, of Triad Radiology Associates in Winston-Salem, North Carolina, wrote at length about participating as a virtual group for a recent analysis in the Journal of the American College of Radiology, explaining everything radiologists need to know about this newest option.

Virtual groups, Golding et al. explained, can consist of any combination of individual MIPS-eligible physicians or groups with 10 or fewer physicians. As long as it’s more than just one person, CMS will consider it a virtual group.

“There is currently no restriction in terms of geography, specialty of the practices, or number of practices that can form a virtual group,” the authors wrote. “Combinations of individual practitioners and small groups of various specialties across the nation could theoretically unite in a single large virtual group.”

Previously established low-volume thresholds are also still in play, so individual physicians or groups with 10 or fewer physicians must still exceed those thresholds to participate as a virtual grid. The rules that determine if healthcare providers are “non-patient-facing” or “hospital-based” also are still intact.

Virtual groups are “assessed and scored” in the same four categories as traditional groups participating in MIPS. Group members, the authors added, responsible for seeing that measures are aggregated across the virtual group.

So, do the authors ultimately think radiologists should participate in MIPS as a virtual group? Golding and colleagues call it “an intriguing new option,” but emphasize that there are pros and cons to consider before physicians dive in. For example, smaller practices must decide how important it is for them to receive the “small practice bonus” from CMS.

“A group that would have been eligible for the small practice bonus reporting as a conventional group will forgo bonus points by electing to join a virtual group that no longer meets the small practice definition,” the authors wrote. “Small practices should weigh the benefit of the special provisions specific to small practices against the benefits of virtual group participation when considering whether to form a virtual group that has 16 or more eligible clinicians.”

Smaller radiology groups have other factors to consider as well, including taxpayer identification numbers (TINs). “A single radiology group with fewer than 10 eligible clinicians but composed of multiple TINs could take advantage of the virtual group option to consolidate TINs,” the authors wrote. “However, radiology groups should consider the trade-offs associated with forgoing small practice status and the logistical challenges associated with forming and reporting within a virtual group when deciding how to participate in the QPP in 2018.”

Radiologists wanting to take advantage of this new option from CMS must make their decision by December of the year before their first potential performance year.

“The submission of a virtual group election must include, at a minimum, detailed information pertaining to each TIN and National Provider Identifier associated with the virtual group and detailed information for the virtual group representative, as well as confirmation of a written formal agreement between members of the virtual group at the TIN level,” the authors wrote.

More information from CMS on virtual groups can be found in the final rule from CMS, available here.