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As discussed previously, it is important to avoid distribution of excessive prepaid shared savings because doing so could result in several undesirable outcomes, such as ACOs accruing debt to CMS that they are unable to repay, which could disruption the ACOs' operations and participation in the Shared Savings Program

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In the CY 2017 Quality Payment Program final rule (81 FR 77539), we codified the definition of improvement activities at 414.1305 to mean an activity that relevant MIPS eligible clinicians, organizations, and other relevant interested parties identify as improving clinical practice or care delivery and that the Secretary determines, when effectively executed, is likely to result in improved outcomes

(ii) Codification of Improvement Activity Removal Factors In the CY 2018 Quality Payment Program proposed rule (82 FR 30056), we solicited comments on the criteria that may be used to identify improvement activities for removal from the improvement activities Inventory, citing that, over time, certain improvement activities should be considered for removal to ensure the Inventory is robust and relevant