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We explained that manufacturers could benefit from a formal process through which they can provide information, including that which may not be publicly available, in order to request an increase in their refundable drug's applicable percentage and provide justification for why the drug has unique circumstances for which such an increase is appropriate, including in the case of a drug with an applicable percentage that has already been increased by virtue of its unique circumstances

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We also do not use the PPIS data for reproductive endocrinology and spine surgery since these specialties are not ( separately recognized by Medicare, nor do we have a method to blend the PPIS data with Medicare-recognized specialty data