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Before we iterate their comments, here are the pertinent details of the Altadis proposal

In the states, the decline in excise tax revenue would be $2.6 billion, the decline in sales tax revenue would be $892 million, and the decline in MSA payments would be $1.2 billion, for a total state revenue loss of $4.7 billion

95% CI: 0.490.88)

To identify the payment amount benchmark period for a Part D rebatable drug, CMS would use the FDA approval date or the first marketed date reported under section 1927(b)(3)(A)(v) of the Act, as applicable

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