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Accordingly, CMS would only permit ACOs that are currently participating in the Shared Savings Program, that have earned shared savings in the most recent performance year for which financial reconciliation has been completed, and that have a positive prior savings adjustment at application disposition to receive prepaid shared savings, as they have the history of success that provides CMS with a more reasoned expectation that they will earn shared savings in the future

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it can cross the placental barrier and affect the fetus, Ahluwalia notes

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