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S2CID 206820997

Our modeling approach utilizes the same scoring engine that is used to determine MIPS payment adjustments

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Specifically, there has been a shift in full time equivalents (FTEs) from physicians to nurse practitioners and a shift from registered and licensed practical nurses to other allied health personnel

CMS continues to be interested in comments on this topic and welcomes additional comments on this approach and alternative approachesspecifically, how CMS should address the situations in which the manufacturer of a Part D rebatable drug does not have an MDRP agreement in effect for any part of the applicable period or when a Part D rebatable drug may be excluded from the definition of a COD and manufacturers may not be required to report pricing and drug product information under section 1927(b)(3) of the Act