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<strong>CMS</strong>-1403-FC<br />

was not practicable due to the complexity of risk<br />

adjustment tasks, coupled with the short implementation<br />

time from passage of MIPPA legislation to the start date of<br />

the Baltimore and Boston program sites. We welcome public<br />

comment on factors to consider for establishing minimum<br />

thresholds, risk adjustment methodologies, and measuring<br />

group practice level resource use.<br />

802

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