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Therefore, we do not anticipate a significant payment impact for these provisions

Zhang, I., Zaorsky, N

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While CMS proposes a 12- and 36-month reconciliation period in the Medicare Part D Drug Inflation Rebate Program, due largely to the 36-month restatement period provided for MDRP AMP restatements (specified in 447.510(d)(3)), CMS does not believe a second or longer restatement process is needed for Part B rebatable drugs because, as described previously, the ASP and claims run-out periods correspond with sufficient claims run-out and ASP restatement timing for Part B (particularly when considering penalties associated with failure to submit timely and accurate ASP data (specified in 414.806(b))