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If CMS grants the rebate reduction request, the rebate amount would be reduced by 75 percent for the duration of 4 consecutive calendar quarters (that is, the calendar quarter in which the event that caused the severe supply chain disruption occurred and the three calendar quarters thereafter), and CMS would not grant any additional reduction under 427.401 for the currently in shortage status during those 4 calendar quarters
The report also looked at other effects, finding a mix of possible risks, upsides and unknowns
We anticipate potential changes to primary care coding and payment policies, such as use of coding that recognizes groups of services furnished over a fixed time period, that would offer a new opportunity within the PFS for primary care clinicians to move to payment structures that are not fully dependent on billing for each discrete component of overall care and act as a step toward accountability for the cost and quality of patient care
Additionally, any payments the ACO receives under this proposal must be repaid to CMS, and CMS would be protected by the ACOs' repayment mechanisms in the event that an ACO does not earn shared savings or cannot otherwise repay the amount owed to CMS
