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Based on our experience with the program and knowledge of the ACOs that participate in it, we expect that estimated impacts will continue and that ACOs reporting eCQMs that would have received health equity adjustment bonus points are poised to have net benefits from the Complex Organization Adjustment

The commenters stated that CMS should explore more sophisticated methodologies, grounded in actual cost data and reflecting real-world complexity of physician practice arrangements, rather than implementing the proposed blanket reduction approach that relies on broad generalizations

ASM risk level means the magnitude of the maximum positive or negative net payment adjustment percentage to which an ASM participant would be subject to during an ASM payment year as described at 512.750(c)(1)(i)