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When OTPs bill the intake add-on code (G2076), we are not proposing to require that OTPs performed SDOH risk assessments in a specific manner, but rather that OTPs continued to perform initial assessment services consistent with SAMHSA certification requirements at 8.12(f)(4)(i) that already largely reflect these type of SDOH risk assessment activities

Section 1899(d)(1)(B)(ii) of the Act also provides the Secretary with discretion to adjust the historical benchmark by such other factors as the Secretary determines appropriate. Pursuant to this authority, over time we have adopted a variety of methods to adjust the historical benchmark to meet certain policy goals

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However, evidence suggests this is not true