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We believe that using a flat adjustment on the final score would be a clear and transparent method to support ASM participants to increase their score relative to other ASM participants so as to avoid potentially creating a barrier for them to achieve a net positive payment adjustment (see section III.C.2.f in this final rule for further discussion on our proposed payment methodology)

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A commenter recommended that CMS only provide an exclusion from reporting to any MIPS eligible clinician, eligible hospital, or CAH that was unable to register for electronic case reporting during the CY 2025 performance period/EHR reporting period in CY 2025