Virtual MIPS Groups Are Now a Reality

Virtual MIPS Groups

For physicians and clinicians participating in MIPS, there is now a new way to join with other healthcare providers, as a result of the new MACRA Ruling.  Small practices, often situated in rural areas, often serve a smaller or more limited number of Medicare and Medicaid patients.  The burden for participating in MIPS can be time intensive and risk these healthcare providers ability to serve these patients to their fullest ability.  

As part of the newly published MACRA ruling and the 26 page CMS Fact Sheet, (which is available for comment until August 18th of this year), solo physicians and groups of 10 or less practicing physicians, can now come together virtually with one or more other solo practitioner or group, to participate in MIPS for one full performance year.

A key note to remember, is that Virtual Groups are not a data submission mechanism.


Requirements for Virtual Groups according the CMS Fact Sheet:

  • You or your practice must elect to participate prior to the performance year
  • You or your practice may not change groups in the middle of a performance year.
  • If you are a member of a group practice (two-nine physicians) elect to participate in a virtual group, all of the physicians in your practice must participate in that group.
  • Virtual Groups must be comprised of TINs
  • Physicians entering into a virtual group, must obtain agreements from CMS.


Initially this was part of the MACRA Legislation’s final ruling, but it had been pushed back until the recent updates to the legislation, published last month.  The ability for these small practices to come together will help them avoid the negative adjustment they would face in 2019, if they had participate or file on their own.


You can find more information on Virtual MIPS groups from the CMS Fact Sheet.