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    MACRA’s virtual groups unveiled


    “I just do not see that many solo physicians, operating under a TIN, and small groups having the time to discuss this and getting to know each other to organize this and then choosing an individual to spearhead this for them,” he said.

    Another uncertainty in the proposed rule is whether physicians are essentially stuck in their virtual group for an entire performance period. While that may be one of the “changes” in the group that requires CMS notification, the proposed rule isn’t clear on the ability or consequences of leaving a virtual group. The rule notes that fluctuations will occur in virtual groups (such as a practice closing) but appears to keep the physician in that group for reporting purposes for the entire reporting period.

    “If you get in, and then six months in you want to get out, I don’t think you can get out. And that’s a concern,” said Cindy Dunn, RN, FACMPE, director of client services for healthcare software provider IntrinsiQ Specialty Solutions in Titusville, Florida. “No offense to physicians, but they like individual reporting because they don’t trust their colleagues. I think for a virtual group, I just think it’s going to be difficult. I understand the concept, but you have to be able to get out if you want to get out.”

    Some of this may get ironed out following the public comment period, which ends August 18.

    Virtual Groups: Can they work?

    One week prior to releasing the 2018 MACRA proposed rule, CMS issued a report on virtual groups, assuming low participation next year, due to many of the factors noted above.

    The agency estimates that only 16 virtual groups would participate, made up of 765 MIPS-eligible physicians across the nation. That’s 0.1% of all eligible Medicare physicians nationwide.

    “We assume that virtual group participation will be relatively low in the first year because we have heard from stakeholders that they need at least three to six months to form groups and establish agreements before signing up,” the document noted. “We are not able to give them that much time in the first year, rather closer to 60 days or potentially less.”

    CMS estimates that those 765 physicians would be ones who participated in MIPS this year, hence familiar enough with the structure and requirements to find potential partners.

    The report also estimates the financial burden for virtual groups, at an annual total of $832 per group, including cost to prepare the formal written agreement and to undergo analysis of the group post-election to verify eligibility.

    “Given that only solo practitioners and groups of 10 or fewer may combine with another group to form a virtual group, I am not sure why a few solo practitioners, that aren’t of the same specialty would want to form a virtual group,” Zetter said. “Even if they were the same specialty, why would they form a virtual group if they didn’t want to be part of the group in a legal way?


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