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chronic blood loss when applicable ✅ Causal relationship documented when coding D63.x (provider must state anemia is “due to” or “in the setting of” the underlying condition) ✅ Drug identified when coding D64.81 (adverse effect code required) ✅ CKD stage documented when coding D63.1 (N18.x must be assigned first) ✅ Polycythemia type specified: vera (D45) vs

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We stated this proposal would provide greater flexibility on the requirement to have 5,000 assigned beneficiaries in each benchmark year, but it also could introduce risk for both the ACO and the program (90 FR 32666)