The Centers for Medicare & Medicaid Services (CMS) has offered independent practices the option to participate in virtual groups, to fulfill the requirements of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Merit-based Incentive Payment System (MIPS). These virtual groups are comprised of ten or fewer independent physicians, with the primary purpose of easing the reporting burden on each individual provider.
However, a recent article in Modern Healthcare notes that “CMS estimates that only 16 virtual groups made up of 765 clinicians will launch by Jan. 1, 2018 to comply with the merit-based incentive payment system (MIPS) under MACRA.” Although the virtual group option was intended to help independent physicians comply with the new requirements, there have been a number of challenges involved. Virtual groups take time to form, as long as three months in most cases, given the need for agreements and coordination.
In addition, independent physicians considering the possibility of a virtual group face the challenge of interoperability between their electronic health record (EHR) systems. Each practice would have to be able to share data with the other practices in the virtual group, for CMS reporting purposes. That data would also have to be standardized across all of the systems in the virtual group. Such standardization and aggregation of data would require a significant financial investment, none of which CMS has offered to subsidize as yet.
Interoperability between physicians coordinating care for a particular patient is an important aspect of EHR use. CMS requirements for a Certified EHR system are designed “to support interoperability and advanced quality objectives in a single, cohesive program that avoids redundancies.” The structure of virtual groups, though, would require interoperability between as many as ten independent practices, in order to meet MACRA reporting requirements. CMS continues to consider exactly how virtual groups would work, including the standards they would have to meet, for 2018 MIPS payments.