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( ( We are seeking comment on whether the proposed elements and requirements are appropriately reflective of care management services for advanced primary care, and whether there are proposed elements of APCM services or proposed practice capabilities that should be modified or removed

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For purposes of calculating the simple average of per capita savings or losses generated by the ACO during the two most recent performance years that have been financially reconciled, we would use all savings generated during each of the 2 performance years in the prepaid shared savings multiplier, not just savings that met or exceeded the ACO's minimum savings rate (MSR) for that prior performance year