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CMS notes that, if CMS were to finalize this alternative approach, CMS would be unable to use this approach to calculate the benchmark period manufacturer price in the case of a new NDC-9 of an existing Part D rebatable drug with base date AMP that does not overlap with the time period described in proposed 428.202(c)(1) or (2)

Wide cuts are long cut, just a little wider

Lastly, we believe this proposal is in alignment with the HHS Overdose Prevention Strategy, which aims to broaden access to evidence-based care that increases willingness to engage and remain in treatment

Under our analysis, our proposed scoring methodology would not negatively impact MIPS eligible clinicians whose average costs for a specific cost measure are around the median

Eisenberg, M