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We were concerned that claim rejections may occur in the absence of a claims modifier to designate that a drug was dispensed, but not administered, by the billing supplier

It is like the three step method but with the first step omitted

(1) CMS will recoup prepaid shared savings made to an ACO from any shared savings the ACO earns until CMS has recouped in full the amount of prepaid shared savings made to the ACO

We propose under 425.672(c) to specify the Shared Savings Program calculations for which CMS would exclude all Medicare Parts A and B FFS payment amounts for the specified ( claim types associated with a HCPCS or CPT code identified in 425.672(b) when an adjustment to the calculation is appropriate in light of the SAHS billing activity