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Another commenter expressed that the requirement to include Type 2 NPIs in the MRF would not make it possible to compare the information with TiC files, stating that TiC requires attributes that specifically define the payer network, plan, and item/service billing class

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This contrasts with procedures performed in HOPDs under the OPPS, where the beneficiary is responsible for copayments that range from 20 percent to 40 percent of the procedure payment (other than for certain preventive services), although the majority of HOPD procedures have a 20-percent copayment