We are concerned that such SAHS billing activity, should it occur in CY 2024 or later, would inflate Medicare Parts A and B payment amounts and affect Shared Savings Program calculations, including: Performance year reconciliation calculations, including expenditures for each ACO's assigned beneficiaries for the calendar year that has SAHS billing activity, the national-regional blended update factor used to update the benchmark for ACOs beginning an agreement period before January 1, 2024 (refer to 425.601(b)), the three-way blended update factor used to update the benchmark for ACOs beginning an agreement period on January 1, 2024 and in subsequent years (refer to 425.652(b)), and factors based on ACO participant revenue to determine the loss recoupment limits for ACOs participating under two-sided models of the BASIC track (Levels C, D, E) (refer to 425.605(d))
Cost measures are calculated by CMS using administrative claims data, and CMS scores MVP participants on all cost measures included in the MVP that they select and report (see 414.1365(d)(3)(ii))
(c) Data Completeness Criteria (i) Data Completeness Criteria for the Quality Performance Category As described in the CY 2017 Quality Payment Program final rule (81 FR 77125 through 77126), to ensure that data submitted on quality measures are complete enough to accurately assess each MIPS eligible clinician's quality performance, we established a data completeness requirement
PMC 535959
