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With respect to the Shared Savings Program calculations, we anticipate that a key focus would be on improper payments pursuant to conduct of individuals or entities performing functions or services related to an ACO's activities as identified in certain False Claims Act (31 U.S.C

Separately, section 3703 of the CARES Act expanded CMS' emergency waiver authority to allow for a waiver of any of the statutory ( telehealth payment requirements under section 1834(m) of the Act for telehealth services furnished during the PHE

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