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CMS also proposes using final action claims from the Medicare fee-for-service claims repository to identify claims where separate payment was allowed for the applicable HCPCS code for dates of service within a year

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Based on further review, CMS has observed that there are several instances where there are multiple manufacturers in a billing and payment code and the ASP data, including the number of units sold, for all or some manufacturers' NDCs within a billing and payment code may be negative, zero, or missing

Under our proposal, we would consider all covered professional services for purposes of attribution, and not solely the limited range of E/M services currently used for attribution