We also note that, while our policy for flat benchmarks for Medicare CQMs described at 414.1380(b)(1)(ii)(F) is only applicable to measures during their first two performance periods in MIPS, as discussed in the CY 2025 PFS final rule, the use of historical benchmarks, when data are available after the first two performance periods in MIPS, will allow ACOs to know the benchmarks prior to the start of the performance year and create opportunities for improvement (89 FR 98120)
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