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For example, payment can be based on 95 percent of Average Wholesale Price (AWP), invoices, or other reasonable payment methods/data made available when the product is contractor priced

CMS has determined that the Federal anti-kickback statute safe harbor for CMS-sponsored model patient incentives ( 1001.952(ii)(2) of this title) is available to protect remuneration furnished in the prepaid shared savings option of the Shared Savings Program in the form of direct beneficiary services that meets all safe harbor requirements set forth in 1001.952(ii) of this title

In response to last year's RFI, most commenters stated that CMS should defer significant changes until the AMA PPIS results become available