Similar to advance investment payments, prepaid shared savings are intended to help an ACO put care processes in place to directly care for the unique needs of the ACO's beneficiary population, it is not intended to solely increase profits or to be spent on items unrelated to the management and operations of the ACO or the beneficiaries it serves
ACOs that prefer to be compared to clinicians at large may do so by reporting eCQMs or MIPS CQMs, for which CMS calculates a benchmark using data reported by MIPS eligible clinicians reporting under the chosen collection type
Similarly, we described concerns that global packages as currently constructed may cause potential distortions in valuation among PFS services, and that the structure of the current packages assumes a single model of care delivery (a single practitioner or other practitioners in the same group practice furnishing the surgical procedure and all associated care) and does not appropriately address scenarios where the surgical procedure and follow-up care are provided by different practitioners in different group practices
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In addition, as outlined in section III.D
