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We note that this Patient Population-Level Management requirement of the APCM services would be met for practitioners billing for APCM services through a TIN that is participating in an ACO in the Shared Savings Program by virtue of the practitioner's participation in the ACO which must meet eligibility requirements for population management, care coordination and quality improvement, including required processes and patient-centeredness criteria in 425.112

Nicotine is addictive regardless of the delivery method, so treat any comparison as a reason for caution, not reassurance

We are not proposing to modify the existing APP quality measure set of six quality measures

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