2025 MIPS Performance Year Virtual Group Election Period
If you’re interested in forming a virtual group for the 2025 MIPS performance year, the election period will begin on October 1, 2024. To form a virtual group, an election must be submitted to CMS via email at MIPS_VirtualGroups@cms.hhs.gov between October 1, 2024, and December 31, 2024 (11:59 p.m. ET).
Is a Virtual Group Required to Submit an Election to Participate in MIPS for the 2025 MIPS Performance Year?
Yes, a virtual group must submit an election to CMS for each performance year it intends to participate in MIPS as a virtual group. Refer to § 414.1315.
If your virtual group was approved for the 2024 MIPS performance year and intends to participate in MIPS as a virtual group for the 2025 MIPS performance year, your virtual group must still submit an election to CMS for the 2025 MIPS performance year between October 1, 2024, and December 31, 2024 (11:59 p.m. ET).
What is a Virtual Group?
A virtual group is a combination of 2 or more Taxpayer Identification Numbers (TINs) consisting of:
- Solo practitioners (defined as the only clinician in a practice) who are MIPS eligible; and/or
- Groups that have 10 or fewer clinicians (at least one clinician within the group must be MIPS eligible). A group is considered to be an entire single TIN.
A virtual group has the flexibility to determine its own makeup.
A solo practitioner or group can only participate in one virtual group during the performance year.
How You Can Benefit from Participating in a Virtual Group?
You can:
- Collaborate, share resources, and potentially increase your performance under MIPS.
- Increase performance volume so you can be reliably measured.
What is the Virtual Group Election Process?
A virtual group must do the following prior to submitting an election:
- Establish a formal written agreement between each TIN within the virtual group (see Agreement Sample Template in the 2025 MIPS Virtual Group Election Process Guide within the 2025 MIPS Virtual Group Toolkit (ZIP, 2MB)).
- Identify an official virtual group representative.
The following elements must be included in an election:
- Acknowledge that a formal written agreement has been established between each TIN within the virtual group.
- The name and contact information for the official virtual group representative.
- The name and TIN for each practice, and all associated National Provider Identifiers (NPIs) under each TIN.
Once the above is complete, the virtual group must submit the election to CMS via email at MIPS_VirtualGroups@cms.hhs.gov by 11:59 p.m. ET on December 31, 2024 (see Election Email Sample in the 2025 MIPS Virtual Group Election Process Guide within the 2025 MIPS Virtual Group Toolkit (ZIP, 2MB)).
Please note that the 2025 MIPS Virtual Group Toolkit (ZIP, 2MB) contains additional helpful information regarding virtual group participation in MIPS, virtual group reporting requirements, the election process, checklists for virtual groups to consider, and sample templates.
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