Virtual Groups and MIPS

by  Wyn Staheli, Director of Research
January 23rd, 2017

During the comment period of the MIPS Proposed Rule (Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models), there were some concerns about NPI and TIN usage for MIPS reporting for smaller organizations.

The following statements are from the MIPS Final Rule regarding these concerns:

"We appreciate the feedback from the commenters. We did not propose an identifier for virtual groups, but in future rulemaking, we will take into consideration the establishment of a virtual group identifier. As noted in this final rule with comment period, the use of the identifiers enables us to identify individual MIPS eligible clinicians at the TIN/NPI level and groups at the TIN level."

"MACRA also provides that solo and small practices may join “virtual groups” and combine their MIPS reporting. Many commenters suggested that we allow groups with more than 10 clinicians to participate as virtual groups. As noted, the statute limits the virtual group option to individuals and groups of not more than 10 clinicians. We are not implementing virtual groups in the transition year CY 2017 of the program; however, through the policies of the transition year and development period, we believe we have addressed some of the concerns expressed by clinicians hesitant to participate in the Quality Payment Program. CMS wants to make sure the virtual group technology is meaningful and simple to use for clinicians, and we look forward to stakeholder engagement on how to structure and implement virtual groups in future years of the program."

To begin this process, CMS will be holding the following webinar for those interested in virtual groups:

Title: Virtual Groups in the Quality Payment Program

Date: Friday, January 27, 2017

Time: 1:00 to 2:00 pm ET

Registration Link:


Virtual Groups and MIPS. (2017, January 23). Find-A-Code Articles. Retrieved from

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