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In all of these examples, regardless of whether the timing of the shortage and submission of the rebate reduction request results in the severe supply chain disruption rebate reduction preceding or following the shortage reduction, CMS intends to continue the shortage reduction clock once it starts for as long as a drug is currently in shortage

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Therefore, we did not propose to establish an average typical dose different than 100 mg for injectable buprenorphine administered on a monthly basis for purposes of calculating the drug component under the OTP benefit, though we solicited comment on whether this average typical dose (100 mg) is close to the dose for the monthly formulation of Brixadi that patients receive on average

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