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We believe these proposals would allow CMS to calculate a payment amount in the payment amount benchmark quarter that aligns with section 1847A of the Act, rather than strictly limiting this calculation to the lower of 106 percent of ASP or 106 percent of WAC as reported for a given drug, as previously stated in the CY 2025 PFS final rule (89 FR 98244), which may not align with CMS' policy for calculating payment limits under 414.904

Another commenter recommended CMS delay the unbundling of G0071 to allow more time to engage interested parties and give consideration to primary care physicians already facing a complex array of coding options for care management

Always adhere strictly to prescribed schedules and concentrations

While these approaches can be effective, they often provide temporary relief and may come with side effects or risks