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Susan Curtis Schneider, [email protected]

We explained that we may take the following approach as one means to operate reopenings in an equitable and manageable manner: In cases where improper payments originated outside the ACO: Generally, we would not seek to reopen payment determinations for any performance year of the ACO's subsequent agreement period in order to mitigate the extent to which we disrupt the administrative finality of payment determinations for ACOs when the improper payments impacting Shared Savings Program calculations originate outside the ACO