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These commenters state that they believe CMS has the authority to require reporting and pay based on ASP

For example, CMS data shows that inappropriate modifier usage on 96372 claims accounts for roughly 10% of all injection-related billing denials

Delayed reporting authorized under our ECE policy allows temporary relief for a hospital, REH, or ASC experiencing an extraordinary circumstance while preserving the benefits of data reporting, such as transparency and informed decision-making for beneficiaries and providers alike

If not, verify the solvent type or allow the vial to rest at room temperature briefly

[DOI] [PubMed] [Google Scholar] 200.Luci S, Hirche F, Eder K

Even if it does move to add BPC-157, doing so requires rulemaking with notices and a comment period