Skip to main content


Quality Payment Program Proposed Rule Introduces Virtual Group Policy

By Arielle Aronson  
   June 26, 2017

Virtual Groups, an element of MACRA introduced in the 2018 Quality Payment Program proposed rule, will affect some MIPS providers who are looking for a way to ease their reporting burdens. 

This article was originally published on Revenue Cycle Advisor, June 26, 2017.

The release of the Quality Payment Program (QPP) proposed rule June 20 unveiled some new additions to the Merit-based Incentive Payment System (MIPS), one of two participation pathways offered in accordance with the Medicare Access and CHIP Reauthorization Act (MACRA).

One of those new features is the introduction of virtual groups, a concept that was mandated by the MACRA legislation. According to MACRA, virtual groups should consist of solo practitioners or groups of 10 or fewer clinicians who come together under “appropriate classifications of providers, such as by geographic areas or by provider specialties” with at least one other solo practitioner or group.

Virtual groups cannot be changed during the performance period, and clinicians may only participate in one virtual group at a time. Virtual groups will report data together for all four performance categories and will receive a composite MIPS performance score. In order to participate, virtual groups must submit written notice to CMS of their intent to report as a group by December 1 of the year preceding the chosen performance period.

The aim of these virtual groups is to ease the burden on smaller practices and providers, but the virtual groups concept was not implemented for the 2017 performance period because CMS said in the 2017 QPP final rule that there was not enough time to implement necessary technological infrastructure to support formation of and reporting from virtual groups for the first transition year. The agency pledged to adopt virtual groups for the 2018 performance period.

The proposed rule also provides more details on how virtual groups will work. CMS proposes that groups opting to participate in a virtual group could include clinicians who would not meet MIPS eligibility as solo practitioners, but the group as a whole would meet MIPS eligibility and must have at least one MIPS-eligible clinician within it. If a solo practitioner alone decides to join a virtual group, however, the clinician must be eligible for MIPS participation as a solo practitioner.

CMS proposes providing technical assistance to virtual groups should the groups need it for the first two years of virtual group inclusion. Any clinician or group choosing to participate in a virtual group for the 2018 performance period must submit written notice to CMS by December 1, 2017. Because the 2018 final rule is not due until the fall, clinicians and/or groups might need to make a decision on whether to participate as a virtual group prior to the release of the final rule.

CMS is soliciting comment on all policies and procedures relevant to virtual groups during the comment period, which will close August 21. 


Get the latest on healthcare leadership in your inbox.