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These concerns aligned with the concerns the Recommendation Group raised about cost measures overall, such as concerns around how cost measures impact patient outcomes

We welcome feedback on this proposed approach and whether there are alternative approaches that may better achieve the agency's goals for application of rebate liability and collection of rebate amount, including whether additional policies and/or a Medicare Prescription Drug Inflation Rebate Program agreement are needed to clarify financial accountability for rebate amounts in situations where there are changes in ownership of a manufacturer or of a rebatable drug

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When the presenting problem for the encounter is for tobacco use the diagnosis should be completely documented with a treatment plan e.g., a cessation program.img1Documentation considerationsDetermine current and past consumptionCigarettesChewing tobaccoPipeNicotine gumE-cigarettesPassive tobacco exposureHistorical tobacco use (how many packs

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