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While we considered a longer period until a revision is completed, such as the 36-month period provided by the MDRP for AMP restatements at 447.510(d)(3), we believe that a 12-month reconciliation period is appropriate for the Part B rebate program because of requirements to submit timely and accurate ASP data (specified at 414.806(b)), and it provides sufficient time to capture the majority of updates to the data specified at 427.301 while closing out (except for the proposed circumstances at 427.501(d)(2) regarding CMS' identification of mathematical errors or manufacturer misreporting) the calculation of the rebate amount for a Part B rebatable drug for an applicable calendar quarter within a reasonable time period after the Rebate Report is issued

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We asked breast medical oncologist Ajit Bisen, M.D., for insight