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EHR vendors have also expressed concerns regarding the need for more time to develop new features that can facilitate eCQM reporting processes

We believe that it would be more accurate to propose the survey 25th percentile work RVU of 9.00 for CPT code 25310 which matches this increase in the total work time

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Reducing the Rebate Amount for Part D Rebatable Drugs Currently in Shortage In proposed 428.301, CMS proposes to codify the policy established in section 40.5.1 of the revised Medicare Part D Drug Inflation Rebate Guidance ( whereby CMS would reduce the total rebate amount for a Part D rebatable drug that is currently in shortage based on the length of time the drug is in shortage during an applicable period and decrease the amount of the reduction over time

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We invite public comment on these four goals