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CMS understands that statutory provisions at section 1860D-14B of the Act require that CMS establish the payment amount benchmark period at the dosage form and strength level, and that resetting the payment amount benchmark period for a new NDC-9 of an existing Part D rebatable drug may not fully align with this directive

Likewise, we do not arbitrarily apply time ratios to current work RVUs to calculate proposed work RVUs

This action cannot be undone

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The following RFIs are issued solely for information and planning purposes