A virtual group is one of several ways clinicians can participate in the Merit-based Incentive Payment System (MIPS). Virtual groups meet the reporting requirements under traditional MIPS; the Alternative Payment Model (APM) Performance Pathway (APP) and MIPS Value Pathways (MVPs) aren’t reporting options available to virtual groups for the 2024 performance year. To receive approval to participate in MIPS as a virtual group for the 2024 performance year, you must submit an election via email ([email protected]) during the virtual group election period, which opens on October 2, 2023, and closes at 11:59 p.m. ET on December 31, 2023.

A virtual group is a combination of 2 or more Taxpayer Identification Numbers (TINs) that elect to form a virtual group for the performance year. There isn’t a limit to the number of TINs composing a virtual group. The composition of a virtual group will be one of the following:

  • Solo practitioners (who are MIPS eligible).
  • Groups consisting of 10 or fewer clinicians (including at least one MIPS eligible clinician).
  • Both – solo practitioners (who are MIPS eligible) and groups of 10 or fewer clinicians (including at least one MIPS eligible clinician).

The election process is the same for all virtual groups, regardless of composition.

Here are some things to consider when forming a virtual group:

  • TINs participating in MIPS at the virtual group level must meet the definition of a virtual group at all times during the performance year.
  • If a group chooses to join a virtual group, all of the clinicians in the group are part of the virtual group.
  • A virtual group might include clinicians who are also participating in Advanced APMs.

A virtual group’s performance is assessed and scored for traditional MIPS at the virtual group level across all 4 MIPS performance categories (quality, cost, improvement activities, and Promoting Interoperability). Virtual groups must aggregate the performance data for all clinicians (across the multiple TINs) within the virtual group for the quality, improvement activities, and Promoting Interoperability performance categories. A virtual group doesn’t need to submit data for the cost performance category because there are no data submission requirements for the cost performance category. We use administrative claims data to calculate a score for the cost performance category on behalf of all clinicians in the virtual group.

Each clinician (National Provider Identifier (NPI)) who is part of a virtual group will receive a final score based on the performance of the virtual group. However, only clinicians who are MIPS eligible will receive a MIPS payment adjustment based on the virtual group’s final score, regardless of any data that may be submitted at the individual, group, or APM Entity level.

Data Collection and Submission Types

There are multiple ways to report data to CMS as a virtual group. The way in which you collect and submit data to CMS depends on:

  • The size of the virtual group.
  • The type of information technology you use.
  • The performance category you’re reporting.

Virtual groups should consider which collection and submission type(s) best fit their virtual group. Virtual groups are encouraged to review the available measures and activities under each collection type(s) to determine which collection type to use and then select a submission type that supports the measures and activities the virtual group would like to report.

Most collection and submission types are available to virtual groups; however, there’s an exception specific to reporting for the quality performance category – Medicare Part B claims can only be used to report quality measures by virtual groups with the small practice designation (i.e., 15 or fewer clinicians in the virtual group).

To learn more about virtual groups, review the resources in the 2024 Virtual Group Toolkit (ZIP, 2MB). [source]