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We are also seeking comment on how we can improve the transparency and predictability regarding which HCPCS codes are considered care coordination services to automate processes downstream for RHCs and FQHCs

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In other words, high-performing ACOs could earn lower measure achievement points relative to comparable MIPS groups because the Medicare CQM benchmarking pool is comprised of higher-than-average performance data-in effect, creating a tournament approach to scoring Medicare CQMs wherein ACOs must compete with other ACOs to earn measure achievement points

Task Force on Community Preventive Services