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Based on his statement and similar opinions from others in the field, it seems that the University of Ottawa might turn out to be more of a nothing burger than a bombshell

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Sections 1848(q)(6)(D)(ii) through (iv) of the Act provided special rules, applicable only for certain initial years of MIPS, for our computation and application of the performance threshold for our determination of MIPS payment adjustment factors

Empirical testing could include assessing whether there are rapid or unprecedented changes to patient case volume or case mix, and the extent to which this could lead to misleading or inaccurate results (86 FR 65508)