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While we understand that there is always a learning curve when new HCPCS codes are introduced, we continue to believe that removing the time-based requirements for HCPCS codes G0568, G0569, and G0570 when billed in conjunction with an APCM base code (HCPCS codes G0556, G0557, and G0558) will ultimately reduce administrative burden, as it aligns the documentation requirements of the APCM codes with the add-on codes

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In response to the CY 2023 PFS proposed rule, a commenter stated that they cannot accurately validate CMS' GPCI calculations because there is little transparency and access to the data and methods used