Virtual Groups Election Period for MIPS 2019 Performance Year Now Open

If you’re interested in forming a virtual group for the 2019 Merit-based Incentive Payment System (MIPS) performance year, the election period is now open. To form a virtual group, you must follow an election process and submit your election to CMS via e-mail by December 31, 2018.

Who Can Join a Virtual Group?

You can participate in a virtual group if you are either:

A solo practitioner eligible for MIPS who exceeds the low-volume threshold; is not a newly Medicare-enrolled clinician; is not a Qualifying Participant (QP) in an Alternative Payment Model (APM); and is not a partial QP choosing not to participate in MIPS.
A group that exceeds the low-volume threshold at the group level (i.e., clinicians under a single Taxpayer Identification Number (TIN) who collectively exceed the low-volume threshold); and has 10 or fewer clinicians (including at least one clinician who is MIPS eligible) that have reassigned their billing rights to the TIN.

Please note: TIN size is based on the total number of clinicians, or National Provider Identifiers (NPIs), billing under a TIN, which includes clinicians who are and are not MIPS eligible.

What is the Virtual Group Election Process?

There is a two-stage election process for forming a virtual group:

Stage 1 (optional):

Contact your Quality Payment Program Technical Assistance organization for information regarding TIN size to help you determine if you meet the TIN size criteria to join or form a virtual group.

Stage 2 (required):

As part of Stage 2 of the election process, you must:

Have a formal written agreement;
Name an official virtual group representative;
Submit the virtual group’s election via e-mail to CMS at MIPS_VirtualGroups@cms.hhs.gov by December 31, 2018; and
Determine if you meet the TIN size criteria and exceed the low-volume threshold

Download the 2019 Virtual Groups Toolkit to learn more about the election process and how to participate in MIPS as a virtual group for the 2019 performance year. The toolkit also contains sample templates for the submission e-mail and the virtual group formal agreement.

Why Join a Virtual Group?

Forming a virtual group gives you the opportunity to effectively and efficiently coordinate resources to achieve and meet requirements under each MIPS performance category, and potentially increase your performance. You can choose the size and composition of your virtual group, and your virtual group may be formed based on location, specialty, or shared patient population.

2018 Virtual Groups - Participation in MIPS

For the 2018 performance year, only a couple of elections for virtual group formation were received as clinicians explored the benefits of virtual groups. Although only a few participated, we were able to gain valuable insights into important considerations for virtual groups. We recognize that the formation of a virtual group requires time and coordination among the small practices within a virtual group. To support the establishment and implementation of virtual groups, free, one-on-one technical assistance is available. We continue to create and provide useful resources and tools that are easily accessible and available for virtual groups. Currently, virtual groups are diligently operationalizing and preparing for the submission of data to meet MIPS requirements.

Need Help?

Request technical assistance from on-the-ground organizations that can provide no cost support.
Contact Quality Payment Program by
Email: QPP@cms.hhs.gov or
Phone: 1-866-288-8292/ TTY: 1-877-715-6222

The Deadline to Submit a MIPS Targeted Review Request is Less than 2 Weeks Away

If you participated in MIPS in 2017, your MIPS score and performance feedback are available on the Quality Payment Program website. The payment adjustment you will receive in 2019 will be based on your score. A positive, negative, or neutral payment adjustment will be applied to the Medicare paid amount for covered professional services furnished under the Medicare Physician Fee Schedule in 2019.

MIPS eligible clinicians or groups (along with their designated support staff or authorized third-party intermediary), including those who are subject to the APM scoring standard, may request for CMS to review their performance feedback and score through a process called targeted review if they believe an error has been made in the 2019 payment adjustment calculation.

Please note, on September 13, 2018, CMS updated MIPS 2017 performance feedback for clinicians affected by scoring issues previously identified through the targeted review process. Additionally, to ensure that we maintain the budget neutrality required by law under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), some clinicians will see slight changes in their payment adjustment factor. If you believe an error exists in your 2019 MIPS payment adjustment calculation, you can request a targeted review by the extended deadline of October 15 at 8:00 PM EDT- which is less than 2 weeks away. To learn more, view this 2017 MIPS Performance Feedback Statement.

When to Request a Targeted Review

The following are examples of circumstances in which you may wish to request a targeted review:

Errors or data quality issues on the measures and activities you submitted
Eligibility issues (e.g., you fall below the low-volume threshold and should not have received a payment adjustment)
Being erroneously excluded from the APM participation list and not being scored under APM scoring standard
Not being automatically reweighted even though you qualify for automatic reweighting due to the 2017 extreme and uncontrollable circumstances policy

This is not a comprehensive list of circumstances. CMS encourages you to contact the Quality Payment Program if you believe a targeted review of your 2019 MIPS payment adjustment (or additional MIPS payment adjustment) is warranted. We’ll help you to determine if you need to submit a targeted review request.

How to Request a Targeted Review

You can access your 2017 MIPS score and performance feedback and request a targeted review by:

Going to the Quality Payment Program website
Logging in using your Enterprise Identity Management (EIDM) credentials; these are the same EIDM credentials that allowed you to submit your MIPS data. Please refer to theEIDM User Guide for additional details.

When evaluating a targeted review request, we will generally require additional documentation to support the request. If your targeted review request is approved, CMS will update your score and payment adjustment factor for 2019 (if applicable), as soon as technically feasible. CMS will determine the amount of the 2019 upward payment adjustments after the conclusion of the targeted review submission period. Please note that targeted review decisions are final and not eligible for further review.

For More Information

To learn more about the steps for requesting a targeted review, please review the following:

Questions?

If you have questions about your MIPS performance feedback or 2017 MIPS score, or whether you should submit a targeted review request, please contact the Quality Payment Program by:

Phone: 1-866-288-8292/TTY: 1-877-715-6222; or
Email: QPP@cms.hhs.gov

CMS Publishes 2018 List of Quality Measures Impacted by ICD-10 Updates

In the CY 2018 Quality Payment Program final rule (82 FR 53716), CMS finalized a process to stabilize measure data throughout the performance period when a measure is impacted by ICD-10 updates mid-performance period. ICD-10 code updates are effective annually on October 1st. An annual review process was established to analyze and assess the quality measures to determine which measures are significantly impacted (determined by a 10% threshold) by ICD–10 code changes during the performance period. If a quality measure is impacted by 10% or more ICD-10 code changes, the performance score for the quality measure will be based only on the first 9 months of the 12-month performance period for those identified measures. CMS has published a list of 2018 quality measures that have been identified as impacted by this update in the Quality Payment Program resource library.

Register Now for the 2019 MIPS Performance Period Self-Nomination Virtual Office Hours Session

Join CMS on October 11th for a Virtual Office Hours Session Regarding the 2019 MIPS Self-Nomination Process

During the 2019 Performance Period Self-Nomination period, CMS will offer a 2019 Merit-Based Incentive Payment System (MIPS) Performance Period Self-Nomination Virtual Office Hours session. The purpose of this session is to allow current and potential Qualified Clinical Data Registries (QCDRs) and Qualified Registries the opportunity to participate in a question and answer session regarding the self-nomination process and its related tasks.

Qualified Registries and QCDRs are CMS-approved vendors that collect clinical data on behalf of clinicians for data submission to CMS for the MIPS program. Please note that eligible clinicians wishing to report for the 2019 performance period of the MIPS program via the Qualified Registry or QCDR reporting mechanism do NOT need to self-nominate. Only entities wishing to participate (and who meet the requirements) as a Qualified Registry and/or QCDR need to complete and submit the self-nomination form. Please attend the session on October 11th from 1-2:30 pm ET if your organization plans to self-nominate as a Qualified Registry or QCDR and you have questions regarding the Self-Nomination process and its related tasks. Participation in this session is optional.

Webinar Details

Title: Self-Nomination Virtual Office Hours Session Webinar
Date: Thursday, October 11, 2018
Time: 1-2:30 p.m. ET
Description: During this session, CMS will provide a Question & Answer Session regarding the self-nomination process and related tasks.
Audience: EHR Vendors, Qualified Registries, QCDRs, Vendor Technology Product Leads, Regional Collaboratives, Specialty Societies, or Large Healthcare Systems
Event Registration: Click here to register.

The audio portion of this webinar will be broadcast through the web. You can listen to the presentation through your computer speakers. If you cannot hear audio through your computer speakers, please contact CMSQualityTeam@ketchum.com. Phone lines will be available for the Q&A portion of the webinar.

For More Information

Visit the Quality Payment Program Resource Library on CMS.gov to learn more about the QCDR and Qualified Registry self-nomination process for vendors.