Medicare QPP

Physicians Advocacy Institute

These resources have not been updated since 2023 but the general details remain relevant. For a summary of the key changes for CY 2024, please click here.

Frequently Asked Questions Updated for 2023

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4. How is scoring determined under a Virtual Group?

  1. Data from all Virtual Group participants will be used to determine the Virtual Group’s performance in each MIPS category and its overall MIPS final score. All practices and eligible clinicians that are participating in a Virtual Group will receive the same aggregated score and related payment adjustment. The exception to this is when a group practice has some ECs who are participating in an APM Entity under a MIPS APM and/or an Advanced APM, and others as part of the Virtual Group.

    In this case where some ECs are participating in a MIPS APM, the scores and related payment adjustments for ECs will be tied to the APM Entity’s performance in the MIPS APM, and the other ECs in the practice would have their scores and related payment adjustments tied to the Virtual Group’s participation in MIPS.   

    Similarly, in the case where some ECs are participating in an Advanced APM, the scores and related payment adjustments for ECs will be tied to the APM Entity’s performance in the Advanced APM. If the EC achieves a Qualifying APM Participant (QP) status, they will be assessed under MIPS as part of the Virtual Group but will be excluded from the MIPS payment adjustment and eligible for the 3.5% Advanced APM incentive payment. If the EC achieves Partial QP (PQ) status, they will be excluded from the MIPS payment adjustment unless the EC elects to report under MIPS by agreeing to participate in a Virtual Group prior to the start of the performance year.

    For additional information see the CMS 2023 Virtual Group toolkit

 




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