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One commenter asserted that studies show that approximately 49 percent of safety net hospitals participate in a Shared Savings Program ACO, and a quarter of all participating Shared Savings Program ACOs include a Federally Qualified Health Center, thus demonstrating that the proposed methodology would not benefit the majority of ACOs serving dually eligible and LIS-enrolled beneficiaries. Several commenters stated that the HEBA as proposed would not go far enoughthat the proposed approach considers too narrow of a population of beneficiaries for purposes of determining eligibility, is likely to benefit too few ACOs, would not adequately account for the expense associated with providing care for historically underserved populations, and is unlikely to drive increased or sustained participation in the Shared Savings Program

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Finally, include vigilance around evolving Medicare vaccine policies

This personalized approach ensures an optimal balance in harnessing the benefits of these injections over time