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( (b) Considerations for Reopening a Payment Determination To Account for Improper Payments In the discussion that follows we describe factors CMS may consider to inform our decision of whether to reopen an initial determination of an ACO's financial performance pursuant to 425.315(a)(1)(i) or (ii) to account for the impact of improper payments that affect the determination of whether an ACO is eligible for shared savings or liable for shared losses, and the amount of shared savings due to the ACO or the amount of shared losses owed by the ACO

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$8.7 billion of that was spent on point-of-sale promotions that have been found to attract youth smokers