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We understand that OTPs have been involved in collaborative agreements with organizations who address HRSN sand offer various recovery support services (84 FR 62648), and we believe that for OTPs to appropriately identify ( these types of organizations that target a specific need, identifying these HRSNs as part of SDOH risk assessments is likely needed prior to engaging in activities to coordinate service delivery

* * * * * (f) * * * (1) An ACO must have the ability to repay all shared losses for which it may be liable under a two-sided model and any prepaid shared savings determined to be owed

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With smokeless tobacco products, the product is kept in close contact with the mucosal lining of the mouth for long durations, resulting in sustained chemical absorption