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In the case of practitioners with low Medicare volume, we anticipate that they would be unlikely to bill for APCM services since the delivery of advanced primary care generally involves time and resources to establish practice-level infrastructure, and the economies of scale usually make this a more likely investment if the infrastructure can be utilized across a larger patient panel

When the risks published by Hackshaw et al

pregnancy tests

Across all practice sizes the proportion of clinicians who do not submit data who receive the max negative payment adjustment decreased between the baseline and proposed policies model

Therefore, we are not proposing any adjustments in burden because we assume the additional cost requirement would not add significant burden to the currently approved 10 hours per application first established in the CY 2018 Quality Payment Program final rule (82 FR 30216)