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We further disagree that the proposed requirements are duplicative of the certification requirement at 180.70(a)(2)(iv) as our stated goal for adding the attester name was to provide further reassurance to the public of the accuracy and completeness of the MRF, while the certification requirement is provided directly and only to CMS under the compliance process

A further discussion of packaged services is included in section II.A.3

Commenters noted that this process becomes even more complicated if MAOs do not pay the hospital based on FFS rates

It typically involves multiple visits with healthcare providers and significant lifestyle changes

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B vitamins including methylcobalamin, niacin, thiamine, riboflavin, and pyridoxine support proper functioning during a calorie-deficient diet