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We proposed at 512.710(b) that clinicians who meet all of the following ASM participant eligibility criteria would be required to participate in ASM: Is a clinician who bills claims under the Medicare Physician Fee Schedule

Response: We appreciate the commenters for the feedback regarding the ASM low back pain quality measures and related concerns

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Therefore, in many cases when we remove 2 minutes of preservice time and 2 minutes of postservice time from a procedure to account for the overlap with the same day E/M service, we also remove a work RVU of 0.09 (4 minutes 0.0224 IWPUT) if we do not believe the overlap in time had already been accounted for in the work RVU