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You must have felt the same need to confirm that we were, as my staff had lately taken to saying five times a day, on the same page, because you invited me into your truck for a few minutes to debrief and get warm

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CMS elected to not propose use of a historical lookback approach (under options 1 and 2) since ASP units are often negative, zero, or missing for the most recent calendar quarter and/or over several quarters in a four-quarter lookback period, and so including additional quarters may not necessarily yield additional data that could be used to apportion inflation rebate amounts (and could complicate the calculation of an average by introducing a mix of zero, negative, missing, and positive units within a single NDC)

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