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The commenters expressed the belief that the 2-year lag time between performance and payment would make it challenging for clinicians to correct course and achieve associated savings

We believe that these policies sufficiently support ACOs in the assumption of risk, and the efficacy of these policies would not be impeded by our proposal to remove the health equity adjustment as discussed in detail in our aforementioned analyses, which indicated that historically, the removal of the health equity adjustment would not have prevented any ACOs that benefitted from the health equity adjustment to meet the quality performance standard

A commenter stated that they do not support the repository because imposing duplicative submission requirements puts the stability of the 340B Program at risk