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At both the 12 month reconciliation point and the 36 month reconciliation point, CMS proposes a reconciliation process that will include: (1) a preliminary reconciliation of the rebate amount, which CMS would provide to manufacturers of Part D rebatable drugs as proposed in 428.401(d)(1)(i) and (d)(2) a reconciled rebate amount, which CMS would provide to manufacturers of a Part D rebatable drug as proposed in 428.401(d)(1)(ii)

If an ACO's maximum quarterly payments decrease over the performance year and result in the ACO receiving less than the estimated annual prepaid shared savings amount, the ACO would not be subject to compliance actions solely because it spent more than 50 percent of the actual annual amount of prepaid shared savings it received during that PY on staffing and healthcare infrastructure, as long as it did not spend more than 50 percent of the originally estimated annual prepaid ( shared savings amount on staffing and healthcare infrastructure

We've seen a massive increase in seizures of illegal products

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