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Response: While we note that APC geometric mean cost changes are expected under the current structure of the C-APCs and the complexity adjustments, we agree that a Level 3 Nerve Procedures APC is appropriate, in particular to resolve what would otherwise be a significant two times rule violation in the Level 2 APC

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(2) the Facility Commitment to Health Equity (FCHE) measure, beginning with the CY 2025 reporting period/CY 2027 payment determination

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