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May be a marker of underlying disease (e.g., liver disease, malignancy, MDS/CML)

Response: As we noted in the CY 2026 OPPS/ASC proposed rule (90 FR 33774), while REHs may have some familiarity and experience with reporting eCQMs when formerly operating as a subsection (d) hospital or a CAH participating in the Medicare Promoting Interoperability Program, we recognize that technological, monetary, and staffing barriers may present challenges to eCQM adoption and use in some REHs

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