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In the CY 2017 PFS proposed rule (81 FR 46162), we requested comments regarding potential alternatives to making adjustments that would recognize overall estimates of work in the context of changes in the resource of time for particular services

Anwar et al

Commenters making this suggestion tended to specify that CMS should apply the policy for reopening ACO payment determinations to address other billing activity that ACOs suspect to be SAHS, citing examples impacting CY 2023 that would not be addressed by the rulemaking to address SAHS billing activity for urinary catheters in CY 2023 (see SAHS billing activity proposed rule, 89 FR 55168), or CY 2024

and services described by CPT code 99211 (office and other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician or other qualified health care professional)

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