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CY 2022 performance data were the most recently available data in time for us to construct our simulation model for this proposed rule and for the same reasons discussed in the CY 2024 PFS final rule (88 FR 79504), we are considering it to construct the baseline and proposed policies model in this proposed rule

(c) Establishing the Performance Threshold for the CY 2025 Performance Period/2027 MIPS Payment Year We believe using the mean of 75 points from the CY 2017 performance period/2019 MIPS payment year continues to be the most appropriate option for establishing the performance threshold for the CY 2025 performance period/2027 MIPS payment year for various reasons described in this section, including: providing consistency for MIPS eligible clinicians while allowing additional time for more recent data to become available, continuing to provide opportunities for MIPS eligible clinicians to gain experience with cost measure scoring (particularly if the methodology proposed in section IV.A.4.f.(1)(d)(ii)(B) of this proposed rule is finalized), and ensuring that we do not inadvertently disadvantage certain clinician types, such as small practices and solo practitioners, as we increase the performance threshold