Should your practice consider a MIPS virtual group?

Mr. Rutherford, former director and founder of the practice management department of the AUA, has been a thought leader and writer on urology management for more than 20 years. Urology Times blogs present opinions, advice, and news from urologists and other urology professionals. Opinions expressed by bloggers are their own, and do not necessarily reflect the views of Urology Times or its parent company, UBM Medica.

Urology practices have always been at a disadvantage when participating in quality reporting due to the shortage of specific urologic measures available in programs such as the Physician Quality Reporting System (PQRS), meaningful use of electronic health records, and now, the Merit-based Incentive Payment System (MIPS).

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By necessity, urologists have been forced to select measures more appropriate for primary care clinicians in order to capture enough data to earn incentives or avoid Medicare payment reductions. For example, the Medicare Urology Specialty Measure set has typically included diabetes, tobacco use, and high-blood pressure screening, all of which would more likely be carried out by a primary care physician. This has required urology practices to gather information from referral sources or conduct additional screening documentation themselves.

What is a virtual group?

For 2019, eligible clinicians are allowed to form what the Centers for Medicare & Medicaid Services (CMS) describes as “virtual groups.” This allows eligible clinicians who have assigned their Medicare payment rights to different taxpayer identification numbers to collaborate and report MIPS measures as a group. The following are the required characteristics of a congregation of eligible clinicians who choose to report MIPS within a virtual group:

• may include solo providers and groups as long as no single group has greater than 10 eligible clinicians billing under a single taxpayer identification number. (This includes non-physician providers as well as physicians eligible to participate in MIPS.)

• Eligible clinicians in a virtual group may be of different specialties and/or primary care disciplines.

• Virtual group participation prohibits clinicians from submitting individual report data, but it does not prohibit individuals from simultaneously participating in an alternative payment model (APM). Involvement in both does require that APM participants also report MIPS performance data through the virtual group.

Next:Virtual group benefits

Virtual group benefits

Urology practices that are struggling to achieve payment increases and bonuses under MIPS for 2017 and 2018 may reap some strategic benefits from taking the lead in forming virtual groups in subsequent years. Among those benefits to be considered are some directly connected with the MIPS reporting rules for virtual groups and others that simply cement professional relationships to ensure consistent referrals from primary care providers in the urologist’s geographic catchment area.

Virtual groups can qualify for MIPS “small practice status” if the total number of eligible physicians in the virtual group is 15 or less, according to CMS. The benefit for those groups that qualify for small practice status is that the Interoperability Performance Category is reweighted to zero for small practices. This category, currently representing 25% of the MIPS final score, is based on the prior meaningful use EHR measures. Providers often consider these the most difficult to achieve under the MIPS program.

For urology practices that don’t operate in rural or Health Professional Shortage Areas (HPSA) but have referral providers nearby that do, there may be a significant benefit in forming a virtual group including those providers if it is possible to recruit many of them. A virtual group that includes at least 75% of eligible clinicians who practice in HPSAs are considered HPSA or rural reporting entities. Virtual groups that qualify as HPSA or rural earn double points on all reported MIPS Improvement Activities, according to CMS.

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Virtual group participation may allow reporting on an expanded number of measures, therefore increasing the reliability due to larger amounts of performance data. In addition, it may spread the cost of reporting over a larger number of clinicians.

Forming a virtual group

The steps necessary to establish a virtual group include naming an official among the participants to serve as the official virtual group representative; preparing and signing a formal, written participation agreement; and submitting the election to CMS before Dec. 31 preceding the first year of reporting. Clearly, there is little time left to start this process from scratch for performance year 2019. However, it would be strategically prudent for urology practice leaders to initiate discussion now while the difficulty of successful MIPS reporting for 2019 is fresh on the minds of potential members of a new virtual group.

More information on virtual groups

To obtain more details, visit the CMS virtual group web page at https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-Virtual-Groups-Toolkit.zip. There, you will find a formal agreement template, an example of the CMS application email, and a process fact sheet.