and Whether and how payment might be limited to a set number of DMHT devices per calendar month per patient
Implementing a similar policy for allowing multiple data submissions in the Promoting Interoperability performance category may provide flexibility for individual MIPS eligible clinicians, groups, virtual groups, subgroups, and APM Entities to fix errors in a prior data submission
The rationale for a financial risk scaling factor of this magnitude is that it enables us to account for a scenario in which an ACO earned zero per capita savings in the performance year that constitutes BY3 of the current agreement period, which is necessarily excluded from the calculation of an ACO's average per capita savings or losses for purposes of the prepaid shared savings multiplier because, as mentioned previously, the performance year that constitutes BY3 of the ACO's current agreement period would not have been financially reconciled at the time of the ACO's application disposition
Further, we believe that payment for oral sleep apnea appliances would not fall within the payment policy for dental services inextricably linked to covered medical services, as the appliances are not services for dental care, but are instead services and supplies for the purposes of directly treating a medical condition unrelated to teeth or structures directly supporting the teeth (for example, sleep apnea)
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