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We further noted that if this proposal were to be finalized, then the quarterly list, starting with performance year 2025 Quarter 4, would be based on the finalized definition of a beneficiary eligible for Medicare CQMs. In the CY 2026 PFS proposed rule (90 FR 32675), we stated that section 1871(e)(1)(A) of the Act prohibits the Secretary from applying substantive changes in regulations retroactively before the effective date of the change except where the Secretary determines, as relevant here, that failure to apply the change retroactively would be contrary to the public interest