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Similarly, we cannot assess what participation levels clinicians or practices who might use these APCM codes have reported MIPS in the past (for example, eligibility requirements and special statuses, participation at the individual, group, virtual group, or Alternative Payment Model (APM) Entity level, or reporting via traditional MIPS, the APM Performance Pathway (APP), or MVPs), or if they will be MIPS eligible clinicians in future years

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In a statement to NPR, a spokesperson for the Department of Health and Human Services said all the committee members have "undergone an ethics and vetting process," and the agency is "committed to robust, transparent discussions about the products." While the panel is tasked with making recommendations, FDA leadership has the final say on what happens