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Comment: A few commenters recommended that we apply OPPS geographic reclassifications and wage index floor policies to ASCs to further harmonize payment systems and mitigate the impact of inadequate wage indices on rural ASCs, noting that hospitals can seek geographic reclassifications and receive wage index floors of 1.0 in frontier States while ASCs are excluded from these protections, despite competing in the same labor markets

Patient consent must be documented in the note

We note that a commenter indicated that the device categories differ in FDA indications

Despite the effectiveness of conventional treatment, there are downsides