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Proposal To Recoup Advance Investment Payments When CMS Terminates the Participation Agreement of an ACO Under current advance investment payment recoupment regulations, there is no clear pathway for CMS to recoup outstanding advance investment payments if CMS terminates an ACO's participation agreement in accordance with 425.218(b)

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And sometimes that meant skating right up to the line of civil rights and liberties, and sometimes it meant crossing it

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It was tempting to draw an easy connection between that reform and the apparent shortage of street Suboxone, but that would be naive