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As a result, we project at least some degree of higher program spending for increased shared savings payments (or reduced loss recoupments) in cases for which CMS decides to reopen the payment determination and issue a revised initial determination to account for the impact of improper payments

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Write the date of reconstitution, the concentration (5 mg/mL if you used 2 mL), and the discard date (28 days from reconstitution as a conservative guideline) on the vial or a label

Comment: A few commenters requested that CMS reconsider the current application requirement of a written spend plan, as it generates additional burden for ACOs