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CMS also considered proposing other alternative policies for attributing rebate amounts to each respective manufacturer in this scenario, including: (1) review of historical ASP data to identify the most recent calendar quarter with positive ASP units for any of the NDCs with negative, zero, or missing units in the applicable calendar quarter and allocation of financial responsibility across NDCs with positive ASP units in that quarter (excluding NDCs without positive units in that quarter)

For comparison, the 2017-based FQHC market basket percentage increase is also projected to be 4.0 percent in CY 2025

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