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(3) Determines the ACO's eligibility for the HEBA based on the proportion of the ACO's assigned beneficiaries for the performance year who are enrolled in the Medicare Part D low-income subsidy (LIS) or dually eligible for Medicare and Medicaid

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To enforce program requirements under 425.110, while still recognizing that variations may occur for an ACO's assigned population, CMS generally issues a warning notice and request the ACO submit a Corrective Action Plan (CAP) should the ACO's assigned population fall below 5,000 beneficiaries

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Understanding your triggers and being honest with yourself and others are key steps in overcoming obstacles