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CMS' decision to reopen an initial determination for a performance year is independent of a determination by CMS to reopen an initial determination for any other performance year, including in cases where multiple performance years are impacted by the same improper payments, whether within the ACO's current agreement period, or a past agreement period

Gurley, Bill J., et al

In fact, the tax is significantly higher on these products than on a pack of traditional cigarettes, which is taxed at $1.01 at the federal level

This is especially true when tax rates in neighboring states are relatively low

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