Optional 2027 MIPS virtual-group election closes December 31
Oct 11, 2026 edition · GC-2026-0306 · Published 2026-10-11 · Version 3 · Announced
Clinicians considering an optional 2027 MIPS virtual group have until December 31 to submit an election. The window opened October 1. The CMS notice directs interested clinicians to its toolkit; it does not automatically enroll them or require every clinician to form a group.
What happened
CMS’s October 8 newsletter announces that the optional 2027 MIPS virtual-group election period opened October 1, 2026. The 2027 participation page sets the closing time at 11:59 p.m. Eastern on December 31. Interested clinicians submit a formal election to [email protected] for CMS approval. This is an election deadline for that reporting option, not automatic enrollment or a requirement that every clinician form a virtual group.
A virtual group combines at least two taxpayer identification numbers, each with ten or fewer clinicians, and must meet CMS’s composition requirements. For 2027, it reports through traditional MIPS; the APP and MVP pathways are unavailable to virtual groups. CMS assesses performance at the virtual-group level, and each MIPS-eligible clinician’s payment adjustment follows that group score even when another participation route produces a higher score under the same TIN/NPI combination. Practices should therefore evaluate their combined reporting and scoring consequences before electing, rather than treating the choice as an administrative filing alone.
Scope and timing
- Authority status
- Announced
- Applicability
- Operationally relevant
- Audience
- Health systems, Provider networks
- Jurisdiction
- Federal
- Affected functions
- Quality, Clinical Operations, Compliance
- Responsible owner
- Quality
- Recorded date
- 2026-12-31
- Date type
- compliance
Why it matters
Eligible practices choosing virtual-group participation must elect by December 31. The option does not impose a new election duty on every clinician.
Recommended action
Evaluate eligibility and coordination needs before deciding whether to elect; follow the CMS toolkit if choosing this option.
Sources
- MLN Connects, October 8, 2026: 2027 MIPS virtual groupsOfficial · CMS · 2026-10-08 · Source review 2026-10-11
- CMS Quality Payment Program: Virtual Group Participation, select performance year 2027Official · CMS · Source review 2026-10-15
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