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For the CY 2026 OPPS update, we identified the APCs with violations of the 2 times rule, and we proposed changes to the procedure codes assigned to these APCs (with the exception of those APCs for which we proposed a 2 times rule exception) in Addendum B to the CY 2026 OPPS/ASC proposed rule

Once a vial is punctured, the sterile seal is broken

While acknowledging that there is not a 2-times rule violation (given the number of single frequency claims for the procedure), the commenter noted that the GMC for CPT code 31647 is significantly above the GMC of the other procedures assigned to APC 5155 and more than double that for many procedures in the APC

[DOI] [PubMed] [Google Scholar] 69.Michaud JL, Boucher F, Melnyk A, et al

Glycyrrhetinic Acid , derived from licorice root, may support anti-inflammatory effects and help reduce fat cell accumulation beneath the skin

As noted by the applicant and acknowledged, CMS has established anatomically specific device category codes in the past, specifically for endoscopes and some ablation catheters