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These recent observations suggest (1) the overwhelming concentration of reported transfer of care modifiers is in ophthalmology procedures, and (2) a potential mismatch in billing for formal transfer of care cases between proceduralists and other practitioners providing post-operative care

-- Causing an ACO that shared savings or owed losses under the initial determination to share in either a higher or lower amount of savings or losses (respectively)

Stakeholders have also noted that patient files exist in multiple, disparate EHRs since each EHR system collects and stores data differently

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