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For instance, if a demanded overpayment determination was for a payment amount on a claim with a HCPCS or CPT code identified as having significant, anomalous, and highly suspect billing activity, and therefore the payment amount was excluded from certain financial calculations used in determining the ACO's financial performance under the proposed adjustment discussed in section III.G.7.d of the CY 2025 PFS proposed rule, we would not include this amount as part of a reopening for the same performance year

Alternatively, CMS could set up marginal savings bands or risk corridors under which shared savings or losses rates would vary with the amount of gross savings or losses

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If the increase from 0.5mg to 1.0mg triggers significant nausea, stepping to 0.75mg first can ease the transition