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CMS elected to not propose use of a historical lookback approach (under options 1 and 2) since ASP units are often negative, zero, or missing for the most recent calendar quarter and/or over several quarters in a four-quarter lookback period, and so including additional quarters may not necessarily yield additional data that could be used to apportion inflation rebate amounts (and could complicate the calculation of an average by introducing a mix of zero, negative, missing, and positive units within a single NDC)

Pharmaceutical retailers counter this argument by reasoning that by selling tobacco, they are more readily able to offer to customers advice and products for quitting smoking

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These benefits positioned vapes as a compelling alternative for traditional smokers seeking change