This commenter stated that CMS has not provided any rationale or explanation for why relying on the updated CBSAs is appropriate and that rather than simply adopting the OMB CBSAs by default, CMS must make a fact-specific determination of those CBSAs' suitability for Medicare payment purposes, including whether it would be appropriate to use additional data to modify OMB's delineation to ensure that such changes are appropriate for purposes of defining regional labor markets for home health workers
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