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One commenter explained that it is important to minimize the reopening of previous years to avoid a perception of instability for the program, and recommended CMS avoid reopening previous years' financial determinations without significant reasons. Response: We appreciate commenters' support for the approach we specified in the CY 2025 PFS proposed rule under which we would consider limiting the instances in which we reopen an initial determination to account for improper payments, pursuant to 425.315(a), to strike a balance between improving the accuracy of the calculations and ACOs' and CMS' interest in administrative finality of payment determinations

Example: E11.40 (Type 2 DM with diabetic neuropathy, unspecified)

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