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Since there could be a variety of reasons for which CMS seeks to recoup an overpayment amount from a provider or supplier, there are many possible circumstances that could warrant reopening under 425.315

To identify the payment amount benchmark period for the purpose of calculating the benchmark period manufacturer price for a subsequently approved drug, CMS would look to the first calendar year beginning after the drug's first marketed date and if no AMP was reported to the MDRP for such NDC-9 for that 4-quarter period, CMS would then identify the payment amount benchmark period as the first calendar year in which such drug has at least 1 quarter of AMP reported