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This could be particularly disadvantageous for ACOs that serve a high proportion of underserved populations because, while ACOs that report eCQMs and/or Medicare CQMs and serve a high proportion of underserved populations are eligible for health equity adjustment points, ACOs must score in the top or middle thirds of ACO measure performers to earn health equity adjustment points

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This code reflects harmful or hazardous use patterns (e.g., legal consequences, impaired functioning, risky behavior) without the hallmark features of dependence, such as loss of control, compulsive use, or prioritization of cannabis over other activities

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Occupational therapy services may be performed by an occupational therapy assistant under the general supervision of the occupational therapist in private practice

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Burden estimates for this proposed rule assume group TIN-level reporting as we believe this is the most reasonable assumption for MIPS eligible clinicians in the Shared Savings Program, which requires that ACOs include full TINs as ACO participants

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