I use the FrameworkElement.IsVisible property. Using the method at the link below, you can also check to see if an element is partially visible(which would be useful in your case):
In WPF, how can I determine whether a control is visible to the user?
You could (by using a background thread or by doing a computation when the user scrolls in the combobox), check the items in the ComboBox to see if their FrameworkElement.IsVisible property were set to true. If so, you update that elements IsVisible property in its ViewModel. Now you have a collection in your ViewModel of items that are marked visible or not(and that are constantly updated concerning the visibility of the CoboBox item that it represents). Now you can find which is the first using .First(x=>x.IsVisible==true) on the collection of items.