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Without this provision, if we keep the existing date of January 1, 2025, as in the current regulatory text at 423.160(a)(5) for the CMS EPCS Program, we estimate at least 6,800 prescribers would become non-compliant due to CMS including prescriptions written for beneficiaries in LTC in the CMS EPCS Program compliance threshold calculation

doi: 10.1111/ijpo.12046 30

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++ Step 5(ii): Weight the risk-adjusted county-level FFS expenditures determined in Step 5(i) according to the ACO's proportion of assigned beneficiaries in the county, determined in accordance with 425.601(d)(1), 425.603(f)(1), or 425.654(b)(1), as applicable, for each of the populations of beneficiaries by Medicare enrollment type

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