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As discussed throughout section II.G.2 of this proposed rule, we believe that the proposed elements of APCM services reflect the comprehensive approach to care management involved in care delivery using the advanced primary care model

The Shared Savings Program continues to receive feedback from ACOs and other stakeholders about the difficulties with reporting on the three all payer/all patient eCQMs/MIPS CQMs and meeting data management requirements given their muti-practice/multi EHR structure

Ideally, there would be MVPs applicable to a diverse set of specialties, patient populations, and clinical conditions

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