Therefore, our proposal would standardize the attribution methodology for QP determinations by making covered professional services the basis for attribution across all Advanced APMs
The measure should account for patients with ocular conditions that impact case complexity to account for patient heterogeneity
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The following formula illustrates how CMS would calculate the AnMP for a Part D rebatable drug as proposed in 428.202(b): (AMP for calendar quarter beginning October) multiplied by (sum of monthly units for October calendar quarter divided by total units for 12-month applicable period) + (AMP for calendar quarter beginning January) multiplied by (sum of monthly units for January calendar quarter divided by total units for 12-month applicable period) + (AMP for calendar quarter beginning April) multiplied by (sum of monthly units for April calendar quarter divided by total units for 12-month applicable period) + (AMP for calendar quarter beginning July) multiplied by (sum of monthly units for July calendar quarter divided by total units for 12-month applicable period) In 428.202(b)(2), CMS proposes that the first applicable period for a Part D rebatable drug will be the earliest applicable period that follows the payment amount benchmark period identified in proposed 428.202(c)(1) through (4)

We also welcome comments on considerations in connection with ACOs' potential role in preventing and reporting Medicare fraud