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The therapists logbook entries substantiate this difficulty, as they reflect the necessity to alter the target phenomenon five times during the treatment period

We believe that this interpretation is based on the certification and recertification requirements under section 1835(a) of the Act as a way to effectuate the requirement in sections 1861(p), (g), and (ll)(2) of the Act that the patient is under the care of a physician, and that the plan of treatment/care for the physical therapy, occupational therapy, or speech-language pathology services has been established by a physician or by a qualified PT, OT, or SLP and is periodically reviewed by a physician

Therefore, our proposal would standardize the attribution methodology for QP determinations by making covered professional services the basis for attribution across all Advanced APMs

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