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We note that an ACO may use prepaid shared savings for staffing, healthcare infrastructure and direct beneficiary services in a manner that complies with the beneficiary incentives provision at 425.304(a), (b), and newly proposed (d) as discussed in section III.G.5.i of this proposed rule, and all other applicable laws and regulations

[12] Wang, H.-T., Wang, P.-H., Chen, C.-Y., Liu, T.-Y., & Tsou, H.-H

Hence, a 1997 headline in the Sarasota Herald-Tribune : Chew Tobaccos Out, but Ballplayers Young and Old Agree That, Whether Its Bubble Gum or Sunflower Seeds, You Need to Jaw on Something. Tobacco is now banned from many Major League stadiums, and it was mostly banned from the sport of baseball itself in 2016, not long after Hall of Famer Tony Gwynn died from oral cancer

We believe that these changes are appropriate as they further account for patient heterogeneity in the more clinically diverse patient cohort