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However, based on 2023 MLR data, we estimate that fewer than half a dozen issuers would meet the new definition of qualifying issuer and, if all of them choose to apply risk adjustment transfer amounts as described and finalized in this rule, would experience a reduction in rebates in a combined total amount of approximately $35 million, out of approximately 180 issuers that owed approximately $946 million in combined total rebates

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Here is my favorite shot from that session

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