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Six members voted against while one member abstained

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Comment: Some commenters agreed that the term upstream drivers encompasses a wider range of root causes of the problems that practitioners are addressing through CHI services, such as potential dietary, behavioral, medical, and environmental drivers to lessen the impacts of the problem(s) addressed in the initiating visit

Comment: A few commenters requested that CMS clarify its expectations regarding the level of active engagement for the CY 2026 performance period/EHR reporting period in CY 2026 in terms of the expectations for MIPS eligible clinicians, eligible hospitals, and CAHs impacted by onboarding difficulties during the CY 2025 performance period/EHR reporting period in CY 2025

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