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Additionally, the projected growth rate from BY 2024 to PY 2025which will be used to update the historical benchmark for PY 2025 financial reconciliation for ACOs that began an agreement period on January 1, 2025would likely also have assumed typical billing patterns for the code in CY 2025 given the projections were finalized early in CY 2025

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The nominator disagreed with the choice of crosswalk CPT code 36440 made by CMS, emphasizing the differences in provider training, procedure risk, and patient population