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CMS welcomes comments on the extent to which, in a scenario where NDCs of multiple manufacturers are assigned to the same billing and payment code, a single manufacturer that accounts for all positive ASP units could potentially be responsible for the full rebate amount for the entire billing and payment code

Further, certain 340B purchases may not be reported to the PVP if those purchases were made through alternative distribution models such as a covered entity purchasing directly from a manufacturer, certain specialty distribution channel purchases, or drugs that receive a 340B rebate under the Ryan White HIV/AIDS Program's AIDS Drug Assistance Program

Due to this change, we also propose to adjust the estimated weighted average time required for each QCDR to submit a QCDR measure from 0.75 hours (10 existing QCDR measures 0.5 hr + 2 new QCDR measures 2 hr) 12 total QCDR measures) to 0.82 hours (11 existing QCDR measures 0.5 hours + 3 new QCDR measures 2 hours) 14 total QCDR measures)

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