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Still chances are just 47

This protects CMS from distributing payments that the ACOs may not be able to repay and the ACOs from accumulating more debt than they can repay through earned shared savings

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We also note that the intensity of CPT code 25310 is decreasing, not increasing, as recommended by the RUC which further suggests that a work RVU of 9.50 would not be appropriate for this code given the surveyed work times

They further asserted that the training and experience levels required to properly perform these procedures differ significantly