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This does not allow for CMS to address SAHS billing activity, which must be addressed prior to conducting financial reconciliation, which is an initial determination, to prevent significant inequity and inaccurate payment determinations

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Impacts of Proposed Changes Related to Advanced Primary Care Management Services In section II.G.2 of this proposed rule, Advanced Primary Care Management (APCM) Services, we are proposing to create three HCPCS codes to use for reporting the proposed APCM services (HCPCS codes GPCM1, GPCM2, and GPCM3) to recognize the resources involved in furnishing services using an advanced primary care delivery model under the PFS