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Multiple commenters requested that CMS revise the complexity adjustment policy by allowing promotion of qualifying code combinations, even when the primary code is already assigned to the highest level of APCs within a clinical family (for example, creating a new APC level to accommodate these higher cost cases)

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Several commenters encouraged CMS to adopt malnutrition quality measures, such as the Malnutrition Care Score (MCS, formerly known as the Global Malnutrition Composite Score) currently used in the Hospital Inpatient Quality Reporting (IQR) program, for the Hospital OQR, REHQR, and ASCQR programs

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