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As discussed in the November 2011 final rule (76 RF 67808), CMS has found [a] minimum threshold is important with respect to both the eligibility of the ACO to participate in the program and to the statistical stability for purposes of calculating per capita expenditures and assessing quality performance. A 5,000 beneficiary minimum, paired with a variable MSR/MLR, enables ACOs to have their work of improving beneficiary care best reflected in their financial performance and shared savings results

Cons: Requires drawing a larger volume for standard doses

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