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Most clinical experience involves short-term therapies, typically for less than a year

Response: In response to the comment that stated that the Complex Organization Adjustment does not capture the full spectrum of challenges encountered by essential hospitals, we note that both the health equity adjustment and the Complex Organization Adjustment upwardly adjust an ACO's MIPS quality performance category score to increase the ACO's ability to meet the quality performance standard, but do not guarantee that the ACO will meet the quality performance standard

These commenters applauded CMS' efforts to align payments between sites of care, stating that payment differentials by site of care increase costs without accompanying quality improvements

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