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CMS-1403-FC
physicians are permitted, what the minimum number of
physicians should be; [16] whether all participating
physicians must be in the same specialty, and, if not, what
issues are raised by protecting arrangements between
hospitals and multi-specialty physician groups; [17]
whether participating physicians should be required to be
on the medical staff at the hospital at the commencement of
the program and, if not, how we should address the risk
that programs will be used inappropriately as recruiting
tools; and [18] whether medical staff members may be added
during an ongoing program and, if so, how we should address
the risk that payments would be made to recruit physicians
from other area hospitals, especially hospitals that might
not be able to afford to offer a similar program.
We also seek comments with respect to limitations on
payments under an incentive payment or shared savings
program. Specifically, we are interested in comments
regarding whether: [19] we should impose a cap on the
payment made per participating physician, regardless of the
amount of cost savings or achievement of patient care
quality goals attributable to a particular physician; [20]
whether payments should be limited in duration and, if so,
whether 3 years or some other period should be the maximum
time period for payments; and [21] whether protected
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