is chewing tobacco worse than dip snuff really safer smoking? Tobacco: No Healthy Alternative

Certain registries have internal data governance standards, including patient safety organization requirements, that they must follow when contracting with single TIN participants that may complicate their ability to support Virtual Group reporting due to necessary legal agreements between solo practitioners and small groups within a Virtual Group (82 FR 53611)

We would perform analyses when the performance threshold changes to set the benchmark ranges

Compare the regional adjustment in accordance with 425.656 and the prior savings adjustment in accordance with 425.658

Failing to apply the proposed changes retroactively to PY 2024 would be contrary to the public interest because it would unfairly punish Shared Savings Program ACOs by forcing them to unexpectedly assume a substantial magnitude of financial risk for costs outside of their control and not previously contemplated in the Shared Savings Program, undermining both the sustainability of the Shared Savings Program and the public's faith in CMS as a fair partner, in the event we determine SAHS billing activity impacts CY 2024

For the APCM services, which are furnished as part of a practitioner's care delivery using the advanced primary care model, we are proposing for practitioners who are MIPS eligible clinicians a practice-level requirement to register for and report the MVP, including but not limited to the PI performance category measures which focus on meaningful use of CEHRT, ensuring that patients/caregivers and physicians or other qualified practitioners or clinical staff have real-time access to patient's medical information

As described above, we are seeking feedback on ways to align the APCM services with other Medicare programs and initiatives, such as the Shared Savings Program and the Quality Payment Program, including MIPS and Advanced APMs