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Procedures that payers treat as investigational for dysphagia generate near-automatic denials, so they don't belong in a clean crosswalk

Although we would not include the informational-only score in cost performance category or MIPS final score calculation, cost measures included in an MVP (that an MVP participant selects and reports) that are in their informational-only feedback period would be treated in the same manner as if the MVP participant was attributed the cost measure under traditional MIPS

To address this limitation, we are adopting the approach recommended by interested parties to use the Shipping Addresses listed for each covered entity in the OPAIS database as an additional location that may dispense 340B-eligible drugs on behalf of the covered entity

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At this time, we are not collecting direct purchase or rebate data in the 340B repository but we note that if ADAPs are covered entities and provide coverage for a Part D 340B claim, they can submit the data elements from that claim to the 340B repository

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