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We believe there still may be situations in which the proposed change in attribution policy would limit QP determinations in certain Advanced APMs, particularly in situations where an Advanced APM is focused on a limited set of services

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As proposed in 428.303(c)(2), a manufacturer must submit the rebate reduction request before the start of the next applicable period in which the manufacturer believes the generic Part D rebatable drug is likely to be in shortage in order for CMS to consider a rebate reduction

Reynolds Smith objects to health advocates referring to the products as candy, saying that will only pique the interest of children