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Grimsrud TK Letter: JOURNAL OF INTERNAL MEDICINE

Using the wage rates in Table 89 of this final rule, we also anticipate collecting a total of 10 rebate reduction extension request forms per year, and a total annual burden estimate of 3,100 hours (310 hr per form * 10 forms) at a cost of $37,378 [(160 hr $84.66/hr for a Business Operations Specialist to collect information and provide brief explanations detailing the specifics of the continued severe supply chain disruption or likely shortage, including determining changes in drug production and distribution and when supply is expected to meet demand, submit information on how the manufacturer plans to resolve or mitigate the severe supply chain disruption or likely shortage, compile supporting documentation providing evidence of the severe supply chain disruption and likely shortage continuation, and submit such information as part of their request to CMS) + (80 hr $129.62/hr for a Pharmacist to to evaluate the continued impact and duration of a severe supply chain disruption or determine the ( continued likelihood of shortage and anticipated duration of the potential shortage) + (50 hr $169.68/hr for a Lawyer to review the submission and determine which information, if any, on the form or in the supporting documentation is considered proprietary and protected under Exemption 3 and/or Exemption 4 of the Freedom of Information Act) + (20 hr $248.94/hr for a Chief Executive to review the Rebate Reduction Request Form and supporting documentation and certify the submission

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(4) comprehensive care plan