- Reminder: Virtual Group Election Period Closes on December 31
- Reminder: EUC Application for 2021 Performance Year Closes on December 31
Please note that early action is encouraged as the QPP Service Center will be closed on December 31 due to the federal holiday.
If you’re interested in forming a virtual group for the 2022 Merit-based Incentive Payment System (MIPS) performance year, you must submit an election to CMS via email by December 31, 2021 (11:59 p.m. ET).
NOTE: A virtual group must submit an election to CMS for each performance year that it intends to participate in MIPS as a virtual group (as required by statute). If your virtual group was approved for the 2021 MIPS performance year and intends to participate in MIPS as a virtual group for the 2022 MIPS performance year, your virtual group is still required to submit an election to CMS for the 2022 MIPS performance year between October 1, 2021 and December 31, 2021 (11:59 p.m. ET).
What Is a Virtual Group?
A virtual group is a combination of 2 or more Taxpayer Identification Numbers (TINs) consisting of the following:
- Solo practitioners who are MIPS eligible (a solo practitioner is defined as the only clinician in a practice); and/or
- Groups that have 10 or fewer clinicians (at least one clinician within the group must be MIPS eligible). A group is considered to be an entire single TIN.
A virtual group has the flexibility to determine its own makeup. A solo practitioner or group can only participate in one virtual group during the performance year.
What Are the Advantages of Participating in a Virtual Group?
Participating in MIPS as a virtual group has the following advantages:
- Can increase performance volume in order to be reliably measured; and
- Provides an opportunity for members of a virtual group to collaborate, share resources, and potentially increase performance under MIPS.
What Is the Virtual Group Election Process?
The following highlights key items that a virtual group needs to complete prior to the submission of an election:
- Establish a formal written agreement between each TIN within the virtual group (see Agreement Sample Template in the Virtual Group Election Process Guide within the 2022 Virtual Group Toolkit).
- Identify an official virtual group representative.
The following outlines the elements that need to be included in an election:
- Acknowledgement that a formal written agreement has been established between each TIN within the virtual group.
- The name and contact information for the official virtual group representative.
- The name and TIN for each practice, and all associated National Provider Identifiers (NPIs) under each TIN.
Once complete, the virtual group must submit the election via e-mail to CMS at MIPS_VirtualGroups@cms.hhs.gov by 11:59 p.m. ET on December 31, 2021 (see Election E-mail Sample in the Virtual Group Election Process Guide within the 2022 Virtual Group Toolkit).
For further information regarding virtual group participation in MIPS, virtual group reporting requirements, the election process, checklists for virtual groups to consider, and sample templates, download the 2022 Virtual Group Toolkit.
- Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours—before 10 a.m. and after 2 p.m. ET.
- Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.
2021 MIPS Promoting Interoperability Hardship Exception and Extreme and Uncontrollable Circumstances (EUC) Applications close on December 31, 2021.
Clinicians, groups, and virtual groups who believe they’re eligible for these exceptions may apply, and if approved, will qualify for a re-weighting of one or more MIPS performance categories.
Alternative Payment Model (APM) Entities can also request reweighting of all performance categories through the EUC application. CMS will notify applicants via email whether their requests are approved or denied.
If approved, the exception will also be added to the QPP Participation Status Tool but may not appear in the tool until the data submission period begins in 2022.
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