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We propose to calculate the prepaid shared savings multiplier as the simple average of per capita savings or losses generated by the ACO during the two most recent performance years that have been ( financially reconciled at the time of the ACO's renewal application disposition, which constitute benchmark year (BY) 1 and BY2 of the agreement period in which the ACO may receive prepaid shared savings (current agreement period, hereafter)

"JUUL Labs does not believe the cases have merit and will be defending them vigorously," stated Victoria Davis, a spokesperson for the company

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Cooper 2014, pp