The Centers for Medicare and Medicaid Services has proposed revisions to the MACRA rule for 2018 that includes virtual groups, something that was unavailable for 2017. While many physicians, particularly in small practices, are generally in favor of virtual groups, guidance on how to join the groups is scant, and it's expected that participation will be small, at least to start.
Virtual groups allow solo physicians, or those in groups of 10 or fewer, to band together for participation in MIPS. A lone physician or group must combine with at least one other physician or group -- location and specialty don't matter -- and have to register before the 2018 performance year. In the case of solo physicians, they have to be eligible for MIPS on their own.
"We've been pushing for years, maybe 10 years or so, for the ability of groups to take advantage of their design and be able t report quality measures to the government as a group," said Robert Tenent, director of health information technology policy for the Medical Group Management Association.
He said a virtual group "wouldn't have the same legal structure as a regular group practice, but they would have the same advantages. It was more complicated than they envisioned, so it was not included in the initial go-'round. It showed up here as a proposal. The question is, how many physicians are going to take advantage of this?"
According to CMS itself, not many. The agency posted a notice on Friday estimating that just 16 virtual groups, 765 clinicians total, will launch by Jan. 1, 2018. As many as 418,000 physicians will be submitting 2017 MIPS data to CMS.
It can take as many as three months to form a virtual group, and many months more to prepare and train staff for the transition, which may translate into a general lack of interest.
"There's not a natural coming together," said Tenent. "The local rheumatologists don't all gather together in the town square to chat. What will be the catalyst to bring them all together? We've not heard specific actions that these trade associations plan to adopt."
A more delineated framework for group formation may spark interest. After all, it's not the concept of virtual groups that has drawn criticism from physicians, but rather the lack of clarity on how it all will work.
"A lot of time it's the logistics," said Tenent. "It's the nuts and bolts the clinicians have to go through to make these things happen. Obviously more guidance would have been better than less. The fact that they've opened up this discussion gives us the opportunity to make some recommendations. We're biased, but we believe the group practice model in general provides higher quality and more efficient care. That may not translate necessarily into virtual groups -- one would argue that maybe being in a virtual group might incentivize them to join a more permanent structure."