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finally, as described for GPCM1, we adjusted this estimate to account for increased frequency of billing (increase from an average of five months of CCM claims per beneficiary to 12 months of assumed practitioner billing for the proposed APCM service, or 237.3 percent)

Stanfill SB, Connolly GN, Zhang L, Jia LT, Henningfield JE, Richter P, et al

CMS proposes to adopt this approach regardless of whether there is a price substitution for Medicare's payment during the quarter or whether other policies cause the published payment limit to differ from the specified amount

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