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We are proposing to include for APCM services the same scope of service elements we established for CCM and PCM services for 24/7 Access ( and Continuity of Care with some modifications

(iii) To determine whether the manufacturer of the drug identified in this paragraph (a)(3) is a first applicant during the 180-day exclusivity period, or whether the manufacturer of this drug is a first approved applicant for a competitive generic drug therapy, CMS will refer to publicly available FDA sources such as the Orange Book and may consult with FDA for technical assistance as needed

We are also planning to reach out to small practices and solo practitioners in CY 2024 to gather additional information about barriers for actively engaging with MIPS

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Are there Health IT functions beyond what is proposed for APCM services that clinicians should be required to have to bill for an advanced primary care bundle