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While we proposed a 12- and 36-month reconciliation period in the Medicare Part D Drug Inflation Rebate Program, due largely to the 36-month restatement period provided for MDRP AMP restatements (specified at 447.510(d)(3)), we do not believe a second or longer restatement process is needed for Part B rebatable drugs because, as described previously, the ASP and claims run out periods correspond with sufficient claims run out and ASP restatement timing for Part B (particularly when considering penalties associated with failure to submit timely and accurate ASP data (specified at 414.806(b))

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