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The defined topped out measure benchmark similarly aims to score clinicians facing limited measure choice on topped out measures using a methodology that adjusts for high performance

While we do not believe there is additional quality reporting for ACO APM entities, consistent with assumptions used in the CY 2021, CY 2022, CY 2023, and CY 2024 PFS final rules (85 FR 84972, 86 FR 65567, 87 FR 70145, and 88 FR 79434, respectively), we include all quality data voluntarily submitted by MIPS APM participants at the individual or TIN-level in our respondent estimates

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