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We find that, in order to comply with the statutory requirements to annually review and update these payment systems and ensure that the payment policies for these systems are effective on an annual basis, we must ensure that the rule is effective no later than 1 full year after the effective date of the previous year's update (that is, January 1 of each year)

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In addition to this research discussed in the FY 2021 rulemaking, we have also considered more recent research comparing Medicare FFS rates, MAO rates, and rates of other commercial payers, some of which used data that was made public under the provisions of the Hospital Price Transparency regulations