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However, the process encountered several challenges, including the gap between design and implementation phases, the exclusion of design actors during implementation and significant changes to the proposed designs

CMS has determined that the Federal anti-kickback statute safe harbor for CMS-sponsored model patient incentives ( 1001.952(ii)(2) of this title) is available to protect remuneration furnished in the prepaid shared savings option of the Shared Savings Program in the form of direct beneficiary services that meets all safe harbor requirements set forth in 1001.952(ii) of this title

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Ishida J, Saitoh M, Ebner N, Springer J, Anker SD, von Haehling S