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A rationale for extending clinical staff beyond the standard 3 minutes for the CA024 activity was absent from the PE Summary of Recommendations, therefore we believe the current and standard 3 minutes is more appropriate than the RUC-recommended 5 minutes

The civil money penalty would be calculated based on the outstanding rebate amount due at the payment deadline, which is defined in proposed 427.505(a) as 30 calendar days after the date of receipt of a Rebate Report containing any rebate amount due

or carrying out any other obligation or duty of the ACO under the terms of the Next Generation ACO model

of this proposed rule): ++ Propose to require Shared Savings Program ACOs to report the APP Plus quality measure set (section III.G.4.b.(2)(a) of this proposed rule)

(3) QP Thresholds and Partial QP Thresholds Section 1833(z)(2) of the Act specifies the thresholds for the level of participation in Advanced APMs required for an eligible clinician to become a QP for a year