MACRA Minute November Newsletter


It’s Not Too Late To Reach Out!

Nervous that the end of the year is rapidly approaching? Feeling behind in your MIPS preparations?  We are here to help talk through your options at this stage in a very practical, reassuring manner. Don’t hesitate to reach out and start a conversation – you’ll be glad you did!

Call the Telligen QPP Resource Center at 844-358-4021 or email us at

Take Action: Apply Now for Virtual Groups Reporting

Solo practitioners and groups have the option to participate in MIPS as a virtual group for the 2018 performance period. To form a virtual group for 2018, solo practitioners and groups must submit their election to CMS by December 31, 2017

What is a Virtual Group?

As outlined in the QPP Year 2 Final Rule, a virtual group is a combination of two or more Taxpayer Identification Numbers (TINs) consisting of: 1) one or more solo practitioners; 2) groups with 10 or fewer eligible clinicians (including at least 1 MIPS eligible clinician); 3) or a combination of both.

To join a virtual group, you must be a:
  • Solo practitioner who exceeds the low-volume threshold; is not a newly Medicare-enrolled eligible clinician (EC), a Qualifying APM Participant (QP), or a Partial QP choosing not to participate in MIPS.
  • Group that exceeds the low-volume threshold at the group level (i.e., the NPIs within the TIN collectively exceed the low-volume threshold) with 10 or fewer clinicians (including at least 1 MIPS eligible clinician).
How Do I Form a Virtual Group?

There’s a two-stage election process:

  • Stage 1 (optional): If you’re a solo practitioner or group with 10 or fewer ECs, you can contact your QPP Technical Assistance representative. Your representative can help determine whether you’re eligible to join or form a virtual group before:
    • Making any formal written agreements
    • Sending in your formal election registration
    • Budgeting your resources for your virtual group

For groups that don’t participate in stage 1, CMS will determine virtual group eligibility during stage 2 of the election process.

  • Stage 2 (required): Submit a formal written agreement between each of the virtual group members prior to submitting an election to CMS.
    • Each virtual group must name an official representative responsible for submitting the group’s election via e-mail to by December 31, 2017.

If all the criteria are met, CMS will contact the virtual group’s representative and provide the group’s performance identifier.

Learn More About Virtual Groups

For more about participating as a virtual group, including the election process and formal agreements, please reference the Virtual Groups Toolkit containing:

  • Virtual Group Participation Overview Fact Sheet
  • Virtual Groups Election Process Fact Sheet
  • Virtual Groups Agreement Checklist
  • Virtual Groups Sample Agreement Template
Need Help with the Election Process?

Contact the QPP Service Center at or 1-866-288-8292 (TTY: 1-877-715-6222) or contact Telligen at 844-358-4021.


Tuesday, December 12 & Thursday, December 14

What: December LAN Webinar: Overcoming Challenges to MIPS Participation

Description: Solo practitioners and small practices have time and resource constraints making it challenging to prepare for MIPS submission by March 2018. This event will focus on what can be done now to prepare for MIPS even if your practice has done little so far and/or lacks a certified EHR.

This event will feature a panel of experts that work regularly with small practices without a certified EHR and limited resources. The panel will focus on ways to avoid 2017 penalties, preparing practices without a certified EHR, and strategies for meeting minimum requirements.

Participants will learn how to:

  • Avoid a penalty, even if no 2017 data has been collected
  • Submit data through your EHR or registry
  • Submit claims data without an EHR
  • Meet the minimum MIPS test pace requirements
  • Address frequent challenges encountered by solo practitioners and small group practices
  • Access free technical assistance and locate a direct support organization funded by CMS

Register Now:

In order to accommodate schedules and time zones, two opportunities will be provided to participate in this webinar. To register for the event, please choose one of the links provided below.

Wednesday, December 6

What: Telligen QPP-SURS Webinar: Final Rule: QPP Year 2

Details: Are there changes from the first year?  What’s new in year 2? What else do you need to know? Did you know The QPP Year 2 Final Rule includes flexibilities to help MIPS- eligible clinicians prepare for full implementation in year 3?

We’re here To help! Telligen’s Michelle Brunsen and Sandy Swallow will be helping small- & solo-practice clinicians better understand the rule and its potential impact.

Key Objectives:

  1. Learn about the key changes between 2017 and 2018.
  2. Understand what the changes mean for Eligible Clinicians.
  3. Explore which changes will be effective for 2017 reporting and what actions you may need to take.

Register Now:

Wednesday, December 6, 12:00 – 1:00 p.m., CST

Deadline: CAH EHR Hardship Exception 

The deadline for Critical Access Hospitals (CAHs) to submit a hardship exception application to avoid the 2016 payment adjustment based on the 2016 reporting year is November 30:

All hardship exception determinations will be returned via email. If approved, the hardship exception is valid for the 2016 payment year only.

For More Information:

QPP Resources: New Location on

To make it easier for clinicians to search and find information on the Quality Payment Program, CMS has moved its library of Quality Payment Program resources to Clinicians will be able to search the library for Quality Payment Program resources by title, topic, or year.

Resources include fact sheets, user guides, and other materials to help clinicians successfully participate in the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs) in 2017.

In Case You Missed It

CMS recently posted the MIPS Claims Data Submission Fact Sheet and Eligible Measure Applicability Toolkit. 

For More Information

  • Visit to check your participation status, explore measures, and to review guidance on MIPS, APMs, what to report, and more.  
  • Go to the QPP Resource Library on to review new and existing Quality Payment Program resources.
  • Subscribe to the Quality Payment Program listserv to receive reminders of important QPP deadlines and program updates. To subscribe, visit CMS Email Updates.


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