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Absent such a threshold, an ACO with a lower than average regional adjustment or prior savings adjustment (and therefore a larger HEBA scaler) that is providing care for relatively few beneficiaries from underserved communities may receive a sizable HEBA, which would reward the ACO despite it not serving a significant proportion of beneficiaries from underserved communities

The countys position was supported by Attorney General Rob Bontas office and a number of health and medical organizations

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