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This approach deviates from the rebate calculation approach set forth in 427.302, which relies on the specified amount defined at 427.20 even when the specified amount and the published payment amount in quarterly pricing files differ

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One commenter further stated that the proposal raised potential safety and security concerns for the hospital executive named on the MRF, noting that requiring a named individual to publicly affirm the accuracy and completeness of complex pricing data could inadvertently expose that person to unintended harm

The commenter stated that this promise of total anonymity could increase distrust for patients, whereas stating that the responses would be confidential both aligns with patients' understanding of how healthcare organizations handle their most sensitive data and also aligns with other CMS patient surveys