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Commenters were concerned about balancing the alignment of the Universal Foundation measures with efforts to reduce administrative burden, potential growth in the number of measures ACOs would have to report, and implementing multiple major changes to the APP quality measure set in performance year 2025

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As noted in section V.B.8.a.(1)(a) of this proposed rule, we have not updated our Quality Payment Program burden estimates to reflect MIPS Promoting Interoperability reporting requirements of non-MIPS eligible clinicians due to requirements for the Shared Savings Program