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One commenter suggested allowing hospitals to select any contiguous 12-month period within the 24 months prior to posting the MRF to allow for delays in payer adjudication

While most hospital outpatient services are payable under the OPPS, section 1833(t)(1)(B)(iv) of the Act excludes payment for ambulance, physical and occupational therapy, and speech-language pathology services, for which payment is made under a fee schedule

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