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If CMS does not make any prepaid shared savings payment, the notice would specify the reason(s) why and inform the ACO of its right to request reconsideration review in accordance with the standards specified in subpart I of our regulations
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We continue to estimate it will take 1 hour for a computer system analyst or their equivalent at a labor rate of $106.54/hr to develop a transition plan on behalf of each QCDR or qualified registry during the self-nomination period
Additionally, we welcome comments on whether these interventions typically occur in the context of an encounter, such as an E/M visit or psychotherapy, or whether there may be times when they may be furnished as a standalone service and whether we should consider allowing this code to be billed on its own
We additionally acknowledge that coding already exists under the PFS that accounts for the resources involved in conducting these types of assessments