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Any risk of higher program spending as a result of finalization of our prepaid shared savings proposal would be fully mitigated by the fact that eligibility would be limited to ACOs that CMS estimates are most likely to earn shared savings, and any prepaid shared savings payments an ACO receives would have to be repaid to CMS

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(4) facilitate Medicare Administrative Contractors (MACs) in processing claims for a MDPP make-up session held on the same day as a regularly scheduled session by requiring use of an existing HCPCS modifier

One potential strategy to increase access to advanced primary care and prepare practitioners in traditional Medicare to engage in more accountable care is through the creation and ongoing refinement of specific billing and coding under the PFS that better recognizes advanced primary care and incorporates the resources involved in furnishing longitudinal care and maintaining relationships with patients over time

Finally, we estimate the number of clinicians who are neither MIPS eligible nor potentially MIPS eligible