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Comment: A few commenters recommended CMS keep the requirement to encode the estimated allowed amount in the MRF instead of replacing it with the median allowed amount and adding the 10th and 90th percentile allowed amounts, indicating they believe that given the volume and complexity of the MRFs, the average would provide a more accurate estimate of what a hospital has historically received for that item or service
A very positive experience overall
The method of administration can be tailored to target specific health concerns
Response: While insurers do not have NPIs, we disagree with commenters that insurers are not required to report NPIs in their TiC files, as they do report pricing information that must be associated with a provider's NPI
Based on established research compounds with decades of individual study data
Systemic effects like fatigue improvement often follow at weeks 4 to 6
