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We note that the existing reopening authority at 425.315 and the proposed financial methodology to address improper payments in such a reopening are not intended to address particular instances of low-value improper payments which, in an individual case may be to the benefit of either the ACO or CMS and in the aggregate are likely have a de minimis net effect on program expenditures in the long run

Things get murky when considering whether smokeless tobacco is better than smoking

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This leads us to the matter of smokers needing their breaks more than non-smokers

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