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The proposal would address the issue discussed earlier in this section whereby, under our current policy, beneficiary attribution for purposes of QP determinations in the default methodology is contingent upon the beneficiary receiving an E/M service, and as a result, beneficiaries who are actually furnished covered professional services by eligible clinicians on an APM Entity's Participation List are not attribution-eligible for purposes of the QP determination if none of the services are E/M services

Specifically, as discussed in section IV.A.4.e.(1)(d)

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