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Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed Direct Contracting – Geographic model, which is part of the Primary Cares Initiative that CMS announced in April 2019. The Geographic option would assign a patient population of at least 75,000 Medicare fee-for-service beneficiaries within a targeted region to an entity that is willing to accept 100 percent up- and down-side risk for spending and quality outcomes. Premier’s comments in response to CMS’ request for information (RFI) focused on these key themes:
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