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Proper documentation is essential to ensure proper reimbursement

A few commenters noted in our proposal in the CY 2024 PFS proposed rule (88 FR 79109 through 79110) their concern about ACOs being compared only to other ACOs that report Medicare CQMs since the Medicare CQMs would be available only to Shared Savings Program ACOs

Commenters stated that it is critical that CMS consider FQHCs' unique Medicare payment structure and that CMS ensure that policy changes for FQHCs are analogous to any changes made under the PFS

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