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As stated in the CY 2025 OPPS/ASC final rule, we will continue to monitor the claims data for these services, anticipating that it may take 3 to 4 years before we see changes in the claims data

The adrenal glands cannot decipher what is happening when in a fight or flight response, so it reacts the same way

FASN-dependent de novo lipogenesis is required for brain development

After considering this issue further since the FY 2022 rulemaking, we do not believe that the current general correlation between the two precludes the ability of this data over time to reflect market-based pricing for at least some services

Response: We note that the two SDOH measures went through the rigorous measure development lifecycle outlined at the CMS Measures Management System website [269] which includes measure testing and reliability analysis

This comparison is intentionally honest