Virtual Group Election Period is Now Open

October 13, 2017


The election period is now open to form a virtual group for the 2018 Merit-based Incentive Payment System (MIPS) Performance Period. The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 allows for the voluntary establishment of virtual groups for the purposes of participating in MIPS.

A provision in the MACRA legislation allows an individual clinician or a group practice consisting of not more than 10 MIPS eligible clinicians to form a virtual group with at least one other clinician or small group practice. The expectation is that virtual groups will help solo and small practices to leverage the benefits of group participation, reduce the administrative burden of participating in MIPS and help improve care coordination.

Virtual groups are not an option in 2017, the first year of the MIPS program. CMS proposed the establishment of virtual groups in the CY 2018 Quality Payment Program (QPP) proposed rule. CMS took the unusual step of implementing the proposal prior to the release of the final rule which is expected to be released in the next few weeks.

To form a virtual group, CMS has proposed a two-stage virtual group election process:

  • Stage 1 (optional): Solo practitioners and groups with 10 or fewer eligible clinicians may contact their designated Technical Assistance representative or the Quality Payment Program Service Center to determine if they are eligible to join or form a virtual group.
  • Stage 2: For groups that choose not to participate in Stage 1 of the election process, CMS will determine if they are eligible in Stage 2. During Stage 2, the virtual group must name an official representative who will submit their election to CMS via email to by December 1, 2017.

For more information about joining or forming virtual groups, see the Virtual Groups Toolkit.

For more information on the CMS Quality Payment Program, visit the McDermottPlus MACRA Resource Center or contact Sheila MAdhani at (202) 204-1459 or

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