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One commenter noted that CMS' proposal does not account for hospitals with integrated healthcare delivery systems which rely on internal allowed amount fee schedules as an alternative, equivalent data source and would produce the same allowed amount outputs as the EDI 835 ERA transaction data, but without significant administrative inefficiencies

For example, injecting B12 into specific acupuncture points rather than a random muscle site can significantly enhance its effects

As a result, this would further widen the disparities in care, especially in rural and underserved communities where treatment options may be limited