Small Practices Can Be Scored Together for 2027 MIPS. The Election Closes December 31 and Holds for the Whole Year.
Solo practitioners and practices with 10 or fewer MIPS eligible clinicians can combine with other small practices and be scored as one virtual group for the 2027 performance year. CMS opened the election on October 1, and it closes December 31, 2026. Once made, the choice holds for the whole year, and everyone in the group shares one score.
In its October 8 MLN Connects newsletter, CMS reminded clinicians that the election period for 2027 MIPS virtual groups opened on October 1, 2026. Elections go by email to MIPS_VirtualGroups@cms.hhs.gov and must arrive by December 31, 2026.
A virtual group lets small practices that are not part of the same organisation report MIPS together and receive one shared score. The 2027 performance year sets Medicare Part B payment adjustments in 2029. CMS has kept the performance threshold at 75 points through the 2028 performance year, and the largest negative adjustment is 9%.
Who can join
Under the MIPS rules, the members of a virtual group are practices, identified by their tax ID (TIN), not individual clinicians:
- A solo practitioner, or a practice with 10 or fewer MIPS eligible clinicians, can join.
- A virtual group needs at least two such members.
- Each practice can be in only one virtual group for a performance period.
- When a practice joins, every clinician billing under its TIN is part of the group.
CMS decides a practice's size and eligibility from its own records. Before agreeing to anything, check each TIN and each clinician in the QPP Participation Status Tool.
What a practice gives up
The election is made before the performance year starts and cannot be changed during it. A practice that joins in December is in the group for all of 2027.
The group is scored as one unit in all four MIPS categories: quality, cost, improvement activities and Promoting Interoperability. Data is combined across every TIN in the group, and each clinician's 2029 payment adjustment comes from that combined score. A partner with weak quality data, or with an EHR that cannot produce the measures, lowers the score for everyone.
The agreement comes before the email
The rules require a signed written agreement between the practices before the election is sent. It must, among other things:
- Name each practice with its TIN and the NPIs of its clinicians.
- Run for at least one full performance period.
- Be signed by a person who can bind each practice.
- Set out each clinician's rights and obligations, including how performance data is combined and handed over if the agreement ends.
- Require each practice to keep its Medicare enrollment up to date and to follow the applicable federal laws.
One named representative then sends the election to CMS by December 31, listing every TIN and NPI in the group. An agreement that takes weeks to draft and sign can miss the date.
A check to run before December
This is general information, not legal or tax advice. A small practice weighing a virtual group for 2027 can start here:
- Look up each TIN and clinician in the QPP Participation Status Tool, and confirm the practice has 10 or fewer MIPS eligible clinicians.
- Pull your own 2025 MIPS feedback and your current 2026 numbers, and ask each possible partner for theirs. Compare quality measures you could report together.
- Ask each partner which EHR and registry they use, and whether that vendor can combine data across practices for one submission.
- Decide who will be the group's representative, who submits the data in 2028, and who pays for what.
- Have the written agreement reviewed and signed by each practice before December. Make sure it covers what happens if one practice leaves.
- Send the election to MIPS_VirtualGroups@cms.hhs.gov well before December 31, and keep a copy of what was sent and when.
- If you decide not to join, note why. You will face the same choice again next autumn.
Practices that are already eligible for a MIPS exception, or that expect to be excluded from MIPS for 2027, should settle that first.
A shared score is a shared risk
A virtual group can spread the reporting work and give a small practice a larger base of patients for its measures. It also ties one practice's 2029 Medicare payments to the habits of practices it does not run. The decision deserves the same care as any contract. If you want a second view of your own numbers before December, a revenue review is a place to start.
Sources
Election period opened October 1, 2026; submit to MIPS_VirtualGroups@cms.hhs.gov by December 31, 2026, for the 2027 MIPS performance year; 2027 MIPS Virtual Group Toolkit.
42 CFR 414.1315, Virtual groups
Solo practitioners and groups of 10 or fewer MIPS eligible clinicians; at least one other member; one virtual group per period; election before the period and not changeable; December 31 deadline; written agreement elements; designated representative submits all TINs and NPIs; data aggregated across TINs and assessed in all four categories.
MIPS performance threshold kept at 75 points for the 2026 through 2028 performance years.
Applicable percent of 9% for MIPS payment year 2022 and each later year; a final score of 0 receives the negative of the applicable percent (maximum negative adjustment 9%).
All figures are as reported by the sources above at the time of writing. Outcome statements reflect typical client engagement outcomes and are not guarantees.
Related reading
- The 2026 MIPS Exception Window Closes December 31. A Hard Year Does Not Have to Cut Your 2028 Medicare Pay.
Your 2026 MIPS score sets your Medicare Part B payments in 2028, with a negative adjustment of up to 9%. If a cyberattack, disaster or other event kept your practice from collecting data this year, the exception applications close December 31, 2026.
- Medicare Appeals Get a New Price of Entry in 2027. Most Practices Lose the Money Long Before It Matters.
CMS has set the 2027 dollar thresholds for Medicare appeals: $200 for a hearing before an administrative law judge and $2,000 for federal court, from January 1, 2027. The numbers barely moved. What decides most practice appeals is earlier: the 30-, 60- and 120-day clocks, and whether small denials are grouped so they can reach a judge at all.
- Medical Coding for the 2026 CMS Fee Schedule
288 new CPT codes took effect January 1, 2026. Here is what changed in the CMS fee schedule, why most practices fall behind, and how to capture the new revenue without inviting an audit.
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