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(i) Proposal To Score for Shared Savings Program ACOs Reporting Medicare CQMs Using Flat Benchmarks In section III.G.4.c.2.c of this proposed rule we are proposing to score Shared Savings Program ACOs reporting Medicare CQMs in the APP Plus quality measure set using flat benchmarks for their first two performance periods in MIPS

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Rather than characterizing this proposal as a presumption, we are taking the view that when the patient's medical record includes a signed and dated written order or referral indicating the type of therapy needed, CMS (and our contractors) would treat the signature on the order or referral as equivalent to a signature on the plan of treatment

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