Fraser Cobbe

Orange County Medical Society

Seminole County Medical Society


The Centers for Medicare and Medicaid Services (CMS) has again signaled their willingness to try to address the administrative burdens posed to small physician practices by the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA). Contained in the 2018 Quality Payment Program Proposed Rule, released at the end of the June, is the framework for small practices to join together in "virtual groups" for purposes of reporting for the Merit-based Incentive Payment System (MIPS).

Significant concern has been expressed from the physician community that the MIPS program will further exasperate the struggles of smaller practices. Given the revenue neutral construct of the Quality Payment Program, the funding for bonuses to be paid to practices with a higher MIPS composite score must come from under-performing practices. The concern is that this sort of competitive landscape may make it difficult for smaller practices to compete with larger groups that have more considerable resources and infrastructure.

The draft proposal from CMS however may provide an avenue for smaller groups to come together and create efficient local partnerships that will provide a platform for sharing the resources and infrastructure necessary to elevate their collective composite scores.

Much more investigation will need to take place on the viability and strategic benefit of smaller practices reporting as part of a virtual group versus reporting individually. But the draft proposal from CMS for 2018 illustrates their appreciation for the concerns being expressed by physicians.

Our local County Medical Societies continue to evaluate programs and services that will assist our members in succeeding in this new payment environment. The OCMS Board of Directors is in the final stages of implementing a benefit program with Mingle Analytics, a national organization with a proven track record of assisting physicians in reporting quality measures to CMS. County Medical Societies could be in a prime position to assist local members in convening virtual groups if this concept emerges as a viable option for our members.

Click here for the link to the official registrar portion of the Proposed Rule discussing Virtual Groups (it's very short). (https://www.gpo.gov/fdsys/pkg/FR-2017-0614/pdf/2017-12229.pdf)